Quarterly Technical Briefing

#2 Winter 2025

Editorial comment

Aidan Golden
Head of Group Technical Services

Welcome to the second edition of Navigator, your trusted source for international industry insights and updates on insurance-based wealth solutions.

Since the launch of Navigator in October 2024, we have been encouraged by the positive feedback we have received. In an ever-evolving landscape, staying informed and adaptable is more crucial than ever. Your support motivates us to continue delivering valuable content in this and future editions.

The current tax and regulatory environments are in a state of constant flux, presenting both challenges and opportunities for our industry. This edition underscores the importance of having a robust technical team to keep abreast of these changes and to assist our partners and their clients in not only staying informed but also in understanding the implications of these developments.

One of the most significant changes in the tax environment is the revamp of the UK non-dom regime. With the upcoming 5 April 2025 deadline, we have included an in-depth analysis to help clients prepare and plan effectively. Additionally, the regulatory landscape is shifting, as evidenced by recent changes in France with the Green Law impacting the advisory model, and in Italy with potential new permissible asset regulations. These topics are covered in detail in this edition, though they continue to evolve.

We are also pleased to feature a contribution from Stephen Atkinson, our Global Head of Sales and Marketing, on the growing private market asset investment sector. His insights into the latest trends, risks, and opportunities are invaluable for advisers looking to navigate this complex area.

Furthermore, we welcome contributions from our new Luxembourg colleagues, whose expertise has significantly broadened the scope and depth of our technical team. Their insights are a testament to our commitment to providing comprehensive and informed guidance to our partners.

We hope you find this edition of Navigator both informative and engaging. As always, we are here to support you in delivering the best possible outcomes for your clients.

Aidan Golden
Head of Group Technical Services

PulseRegulation, Tax and ComplianceCountry FocusTechnical SpotlightCase Study InsightsUpcoming Events Download PDF

In this issue

Pulse

The key developments in regulation, tax and compliance by market.

Regulation, Tax and Compliance
Country Focus
Technical Spotlight
Case Study Insights
Upcoming Events

Upcoming webinars and other industry events

Ask Our Team

Get in touch with the Technical Services team

Pulse

Keep your finger on the industry pulse with our quarterly round-up of the most important regulatory and compliance developments in the wealth management sector.

Updated quarterly, this overview reflects the position at the time of publication.
For the latest developments, please refer to the most recent edition.

UK
Advice Guidance Boundary Review update

Next steps set out in FCA’s work to close the ‘advice gap’.

15 November 2024

  • FCA have identified a gap in provision of financial advice.
  • Review aims to look at targeted support for certain groups, developing concept of ‘simplified advice’ and further clarifying boundary between regulated advice and non-regulated support.
  • Plan to consult on rules for better support for consumers in retail investments and pensions in H1 2025.

UK
Financial Conduct Authority Crypto roadmap

Timeline of planned policy publications for cryptoasset regulation.

26 November 2024

  • Sets out key dates for expected discussion papers and consultation papers in development of new UK crypto regime.
  • Designed to increase consumer trust and ensure market integrity.

UK
Financial Conduct Authority (FCA) Anti-Greenwashing Rules

Sustainability disclosure and investment labelling regime for funds.

02 December 2024

  • Naming and marketing rules come into force for fund managers.

UK
Solvency II UK Regime

Solvency II regime reforms come into force (with some exceptions).

31 December 2024

  • Reforms include certain provisions of the relevant Statutory Instruments (SIs) and revocation of Solvency II assimilated law.
  • PRA have published policy statement PS15/24 – Review of Solvency II: Restatement of assimilated law.
  • Sets out conclusions for Solvency II Review including final rules, reporting and disclosure templates and policy material.

UK
UK PRIIPs Revocation and Replacement Disclosure Regime

Consultation Paper on new disclosure regime to replace UK PRIIPs published 19 December 2024, responses by 20 March 2025.

2025

  • FCA consultation document on a new consumer disclosure regime released with draft rules
  • Term ‘PRIIP’ being replaced with ‘consumer composite investments’.
  • Proposal to replace PRIIPS KID and UCITS KIID with a product summary.
  • FCA also consumer testing their proposals.
  • The existing exemption for UK UCITS Funds in providing a UK PRIIPs document expires in 2027.

UK
Removal of remittance basis of taxation and moving to a residence based system for UK IHT.

UK Long-term residents no longer able to benefit from remittance basis. IHT system changed to a simpler residence-based system.

06 April 2025

  • UK IHT moves from domiciled-based system to residence based system from 06 April 2025.
  • Excluded Property trust and UK Trust Protections removed from 06 April 2025 – property will be in scope for IHT based on a person’s long-term residence.
  • Remittance basis removed from 06 April – FIG regime introduced to allow arrives who have been non-resident for 10 consecutive years to benefit from four years of tax relief.

EU
Sustainable Finance Disclosure Regime (SFDR) Changes

ESAs propose SFDR changes.

31 July 2024

  • The European Supervisory Authorities (ESAs) have proposed several changes to the existing SFDR, including a simplified categorisation system.
  • These proposals contribute to the European Commission’s ongoing review of the SFDR and its effectiveness.

France
Green Industry Law No. 2023-973 of 23 October 2023

Greater transparency within policies and funds.
Changes to the information provided to customers prior to the purchase and sale of a fund within a life insurance policy.

24 October 2024

  • Greater transparency and clear communication on surrender penalties on life insurance policies or funds.
  • New rules on the pre-contractual information that must be provided to customers.

France
Green Industry Law no. 2023-973 of 23 October 2023

Reinforcement of “the duty to advise”.
Creation of a financial profile for the customer, to be updated proactively.

24 October 2024

  • Introduction into French law of a range of measures requiring regular updating of the information collected from policyholders throughout their investment life.

Italy
Draft 2025 Budget

Significant changes to collection of Stamp Duty payments.

October 2024

  • Draft 2025 Budget included significant changes to the timing of Italian Stamp Duty payments
  • The budget imposes an obligation on insurance companies to prepay policyholder stamp duty liabilities accrued from 2012 to 2014 and introduces a new obligation to pay SD on annual basis from 2025 onwards.
  • Final Budget expected to be published by the end of 2024.

France
Special law on the French budget 2025

Avoiding shutdown in France.
No confidence vote against the government had prevented the adoption of the Finance Bill for 2025: special law will allow the 2024 budget to be extended to 2025 until a new budget is adopted.

31 December 2024

  • This special law can be used when the state finds itself without a budget on 01 January, in order to avoid administrative paralysis.
  • It is not political in nature and contains only three articles.
  • The first measure is to authorise the government to ‘continue to collect existing taxes’ until a budget has been voted.
  • The other two provisions enable the State and Social Security to borrow on the financial markets, via their dedicated agencies (AFT and Acoss), in order to avoid defaulting on payments.

Italy
Institute for the Supervision of Insurance (IVASS)

Second Consultation on revised set of rules on permissible assets and investment restrictions for index and unit-linked products.

December 2024

  • Almost two years since the first consultation in 2022, IVASS launched a second public consultation in March 2024 (closed May 2024) on revised rules for permissible assets, investment restrictions for index and unit-linked products, and its views on biometric risk requirements. Once approved, these will apply to both domestic and EU insurers operating in Italy on a FoS basis.
  • Utmost provided feedback to the Regulator on the revised rules, aiming to minimise the impact the proposed changes might have on the Italian product and market.
  • In a recent meeting with Insurance Ireland and Financial Services Ireland, IVASS confirmed its ambition to issue the final regulation by the end of this year, reaffirming their intention not to adjust the scope of the regulation.

EU
Digital Operational Resilience Act (DORA)

Deadline for compliance.

January 2025

  • DORA ensures the resilience of financial services firms during operational disruptions. It focuses on IT risk and incident reporting, setting technical standards.
  • Firms must comply with these regulations by January 2025.

EU
Corporate Sustainability Reporting Directive (CSRD)

Large companies required to track CSRD data for 2026 reporting.

France

  • CSRD requires EU firms, including qualifying EU subsidiaries of non-EU businesses, to disclose their environmental and social impacts in a standardised format.
  • Additionally, firms must report on how their business is affected by their environmental, social, and governance (ESG) actions.
  • This directive aims to drive transparency and accountability within firms and increase the focus on sustainability.
  • The reporting deadlines for the CSRD depend on the size of the entity. From 01 January 2025, large companies (250+ employees) must track CSRD data for 2026 reporting.

EU
Publication date of Omnibus Simplification Package

Proposed Omnibus regulation to cut ‘red tape’.

26 February 2025

  • Omnibus Simplification Package’ expected to be published.
  • Expected to look at Taxonomy regulations, the CSRD and CSDDD.
  • Aim to reduce bureaucratic burden without changing the content of the law too much,
  • Unclear at this stage what changes the Commission is planning to make.

France
Green Industry Law no. 2023-973 of 23 October 2023

Transaction fees banned for arbitrage mandates.
Introducing a DDA interpretation within French law on life insurance dealing charges (in arbitration mandates).

1 January 2026

  • Transaction costs on traditional private bank accounts managed on a discretionary basis are still permitted in France.
  • Transaction costs will be prohibited on discretionary managed life insurance policies from 01 January 2026.

EU
Artificial Intelligence (AI) Act

Majority of provisions in the Act to take effect.

02 August 2026

  • Published in the EU Official Journal on 12 July 2024, the AI Act classifies AI systems based on their potential risk, banning those with unacceptable risk and regulating high-risk systems.
  • Applies to all organisations that develop, use, distribute, or import AI systems in the EU, even if they are not EU-based.
  • Legal application to be phased in over the next three years, with most provisions taking effect on 02 August 2026.

EU
Retail Investment Strategy (RIS)

Retail Investment Strategy PRIIPs and IDD changes.

2027

  • RIS aims to boost consumer protection and confidence in the financial sector through enhanced disclosure requirements and financial promotion rules, for example, to encourage customers to invest in financial products across the Union. It has two main components:
    • The Omnibus Directive, which significantly amends IDD, MiFID II, UCITS, AIFMD, and Solvency II.
    • Amendments to the PRIIPs Level One Regulation, paving the way for new technical standards
  • Negotiations on aspects such as inducement rules and value-for-money benchmarks have been intense. The EU ‘trilogue’ negotiations are expected to begin in November 2024, following the new Commission’s term commencement.
  • Given the complexity of these legal updates, the strategy is not expected to be in effect until 2027.

EU
EU Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT)

6th AML Directive (AML D6) and new AML Regulatory Package.

2027

  • This package includes a directive outlining the mechanisms member states must implement, a regulation establishing the Authority for AML and CTF, and a significant regulation to replace the current Fifth AML Directive.
  • The new regulation aims to address inconsistencies in the local application of the directive by introducing directly applicable rules across the EU. This will be supplemented by sets of yet-to-be-published Regulatory Technical Standards.

Malaysia
Guideline related to Income Tax
(Exemption) (No. 6) Order 2022 (Amendment) Order 2024

Clarified tax treatment for foreign income.

June 2024

  • Foreign income received in Malaysia by residents will be taxable, with certain exemptions for foreign dividend income and other specified conditions.
  • Detailed guidelines issued for the tax treatment of foreign income received in Malaysia, including exemptions and record-keeping requirements.

Taiwan
CFC Reporting for Offshore Trusts

Tightened tax rules for offshore trusts held by Taiwanese residents.

July 2024

  • New ruling issued by the Ministry of Finance supplementing the CFC ruling in January 2024 that imposes Alternative Minimum Tax (AMT) on the settlor/beneficiaries of offshore trusts when CFC is involved.
  • Offshore trustees must register with Taiwan tax authorities, prepare accounts and detailed income and distribution statements for all trust assets. Trustees without a presence in Taiwan must appoint a local agent.

Hong Kong
Proposed Company
Re-domiciliation Regime

New regime to allow foreign companies to change their place of incorporation to Hong Kong.

July 2024

  • Streamlined process for businesses to re-domicile to Hong Kong.
  • Applies to foreign companies of different types and scales.
  • A comprehensive regime follows the fund re-domiciliation regime implemented in November 2021 which established a simplified fund re-domiciliation regime for Open-Ended Fund Companies and Limited Partnership Funds.

China
Enforcement of Six-Year Rule

Taxation on global income for long-term foreign residents.

December 2024

  • Six-Year Rule introduced from January 2019. 2024 marks the first year that this rule is applicable.
  • Foreigners residing in China for more than 183 days per year for six consecutive years will be taxed on their global income. The six-year period can be reset by leaving China for more than 30 consecutive days.

Singapore
Family Office Tax Incentives Economic Criteria for Qualifying Funds

Extension and revision of tax schemes.

January 2025

  • Changes to economic criteria for sections 13D, 13O, and 13U to take effect from January 2025.
  • Extension of tax incentives for qualifying funds until end of 2029.
  • Inclusion of Limited Partnerships under section 13O scheme.
  • Revised economic criteria for qualifying funds, including potential introduction of a minimum fund size and increased business spending commitments.

Hong Kong
Family Office Policy Further Review and Tax Concessions

Enhanced measures and tax regime for family offices.

May 2025

  • Ongoing measurement of the Capital Investment Entrant Scheme (CIES) and Family-owned Investment Holding Vehicles (FIHVs) introduced in March 2024.

Thailand
Potential New Law on Foreign Income

Comprehensive taxation on foreign income.

2025>2026

  • Further revision of foreign income taxation effective from 01 January 2024. Foreign income brought into Thailand will be taxed in the year it is brought in, regardless of when earned. This eliminates the previous tax deferral strategy.
  • Proposed amendments may require individuals residing in Thailand for more than 180 days to pay tax on foreign income, even if not brought into Thailand. This is still in early legislative stages.

Regulation, Tax and Compliance

The New Landscape of UK Retirement Savings

Glenn McIIroy
Technical Services Manager

Brendan Harper
Head of Asia and HNW Technical Services

Pension policy in the UK has undergone significant shifts recently, reflecting a change in government and differing priorities. The first Labour budget in 14 years expanded taxation on pensions, moving away from the Conservative approach of encouraging pension savings and longer workforce participation.

Let’s look at what has changed over the past two years and examine the impact on pension savers in the UK and beyond.

Read the article

Last Call for Spanish Golden Visa: Key Changes and Urgent Actions

Nerea Llona
Tax and Legal Counsel – Spain and LatAm

The Spanish government has officially announced the termination of the Golden Visa – investor visa scheme. This significant change, published in the Spanish Official Gazette on 3 January 2025, will come into effect on 3 April 2025. This update provides crucial information on the upcoming changes.

Read the article

IVASS Expands Regulatory Reach on Investment Limits: What Does It Mean for EU Insurers?

Filippo Mancini
Senior Wealth Planner Italy

Filippo Mancini examines the latest regulatory shift by IVASS, which proposes new investment limits for unit-linked insurance products. This development challenges the principle of home country control and raises important questions for EU insurers, particularly those based in Luxembourg and Ireland.

Read the article

Understanding the Debate on Belgium’s Branch 6 Capitalisation Contracts

Nicolaas Vancrombrugge
Senior Wealth Planner – Belgium and Luxembourg

Nicolaas Vancrombrugge looks at the latest developments in the Luxembourg Branch 6 capitalisation contract and the ongoing regulatory debate with the Belgian Financial Regulator (FSMA). This article explores the implications for Belgian corporate entities and the positions of both the FSMA and the Luxembourg insurance sector.

Read the article

Country Focus

UK: Changing Times – Overview of the UK Autumn Budget

Simon Martin
Head of UK Technical Services

Simon Martin, Head of UK Technical Services, provides an overview of the key personal taxation measures from the UK Autumn Budget and their implications for investors and estate planning.

Read the article

UK: Expat Advantage – How Long-Term Expatriates Benefit from New IHT Rules

Brendan Harper
Head of Asia and HNW Technical Services

Amid predictions of a mass exodus of foreign HNW individuals from the UK following the UK Budget, long-term UK expatriates have a reason to celebrate.

Brendan Harper, Head of Asia and HNW Technical Services, explains how the break in the link between UK domicile and Inheritance Tax significantly benefits expatriates, allowing them to plan with certainty and avoid the complexities of the old tax regime.

Read the article

Finland: Unit-Linked Life Insurance: Unlocking Benefits for Finnish Investors

Jari Vill
Tax and Legal Counsel Scandinavia

Unit-linked life insurance offers significant benefits and flexibility for clients in Finland, providing long-term savings and investment solutions. With advantages such as gross roll-up, VAT exemption on asset management fees, and simplified inheritance planning, these policies are designed to meet the needs of a mobile and international population.

Jari Vill, Tax and Legal Counsel – Scandinavia, explains the tax implications and compliance requirements for clients when moving to or from Finland and how advisers can help maximise the benefits of their life insurance policies through proper planning and adherence to local regulations.

Read the article

Asia: Sustainable Wealth Management for HNW Families in Asia

Peter Tung
Tax and Legal Counsel – Asia

Sustainable wealth management is crucial for high-net-worth (HNW) families in Asia, given their unique and complex needs. In this article, Peter Tung looks at the strategies for securing long-term financial health, optimising wealth transfer, and maintaining privacy amid evolving regulatory environments.

Read the article

Spain: Supreme Court Decisions on Unit-Linked Life Insurance Contracts – Key Takeaways

Ester Carbonell van Reck
Senior Wealth Planner – 
Spain and LatAm

The Spanish Supreme Court has recently issued two significant decisions regarding the legal nature and tax implications of unit-linked life insurance contracts. These rulings clarify that unit-linked contracts are indeed life insurance contracts and, before 2021, were not subject to Spanish Wealth Tax if they had no right of surrender.

In this article, Ester Carbonell van Reck examines the details and implications of these decision

Read the article

Spain's 2025 Tax Rate Increase for Savings and Gains

Nerea Llona
Tax and Legal Counsel – Spain and LatAm

Nerea Llona examines Spain’s 2025 tax rate increase for savings income and capital gains. Effective 1 January 2025, the maximum Personal Income Tax rate for savings income and capital gains exceeding €300,000 will increase from 28% to 30%. In this update, Nerea provides the relevant information on these upcoming changes.

Read the article

Sweden: Yield Tax Rate 2025 Set at 0.888% – What You Should Know

Jari Vill
Tax and Legal Counsel Scandinavia

Discover the key updates to Sweden’s yield tax rate for 2025 and what it means for the life insurance policies of Swedish clients.

Read the article

Technical Spotlight

Strategic Wealth Management and Global Mobility: Navigating Trends and Opportunities

Stephen Atkinson
Global Head of Sales and Marketing

Private Market Assets and International Bonds – Putting your Clients in Control of the Opportunity

Navigating global wealth trends can be challenging in the fast-paced financial services market. However, one promising area for financial advisers is the growing private market asset investment sector. This market is global, cross-border and expanding rapidly, though it comes with its own unique set of complexities and considerations.

In this article, Stephen Atkinson, Global Head of Sales and Marketing at Utmost Wealth Solutions, examines the latest trends, the risks and opportunities, and suggests how international bonds, paired with private asset investments, could serve as complementary planning tools.

Read the article

Brendan Harper
Head of Asia and HNW Technical Services

Global Wealth Migration: Top Destinations and Key Considerations for HNW Families

Over 135,000 millionaires are predicted to migrate from their country of residence in 2025, with China and the United Kingdom1 seeing the largest outflows. These “net outflow” figures are counterbalanced by countries experiencing “net inflows”.

So, which countries are set to benefit from these inflows, what are the main attractions and considerations, and how can we help support you and your clients?

Read the article

Case Study Insights

Brendan Harper
Head of Asia and HNW Technical Services

Maximising Returns for a Global Investor

In our Technical Spotlight section, Stephen Atkinson examined the growing private market asset investment sector and how international bonds, paired with private asset investments, could serve as complementary planning tools.

Selecting the optimal structure to hold private market assets is crucial for wealthy clients. This case study demonstrates how an international bond stands out as a potentially efficient solution.

 

Read the Case Study

Jari Vill
Tax and Legal Counsel Scandinavia

Swedish IT Entrepreneurs’ Smart Exit Planning from a Holding Company

Sofia, 43, and Peter, 58, have run a successful IT company in Sweden for 15 years. They recently sold the company and are now looking to manage the proceeds efficiently to minimise taxes when withdrawing funds. They have heard of the possibility of placing the proceeds into a holding company.

This case study explores the solution of placing the proceeds into a tailored offshore bond via a holding company and the benefits it offers.

Read the Case Study

Events and Webinars

Stay updated on our webinars and other industry events where Utmost will have a presence.

Market
Event
Date

France

IPEM Wealth Cannes | 2025 Conference

28-30 January 2025

Find out more

France

La Rencontre Occur Région (Aix en Provence)

30-31 January 2025

Find out more

UK

Utmost Wealth Solutions webinar – Planning for the New Tax Year: Challenges and Opportunities from the Labour Government’s Budget

5 February 2025

Find out more

Luxembourg

Family Office & Asset Management Summit

18 March 2026

Find out more

Luxembourg

Luxembourg Wealth Management Awards

18 March 2025

Find out more

France

Université CNCGP Paris

9-10 April 2026

Find out more

Technical ServicesTeam

We provide expert, timely support for partners in the high and ultra-high net worth market through one of the most qualified Technical Services teams in the industry.

To contact the team, simply get in touch via the Ask Us Anything form below.

Meet our technical experts

  • Day to day technical support

  • Inheritance tax and wealth transfer planning

  • Online technical portal

  • European portability review service

  • The latest regulatory and tax developments

  • Product structuring to address specific client needs

Ask us anything

If you have suggestions for the next edition or questions, don’t hesitate to contact the Technical Services team.