Quarterly Technical Briefing

#3 Spring 2025

Editorial comment

Aidan Golden
Head of Group Technical Services

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

In this edition, our Technical Spotlight section focuses on gifting. In an ever-changing tax and regulatory environment, clients need to plan robustly for the effective and tax-efficient transfer of wealth to preserve their family legacy across generations.

An insurance solution can be a valuable tool in ensuring assets are passed on efficiently whilst maintaining control over access. However, complex and evolving tax and regulatory regimes can make this area of planning as challenging and time-consuming as it is rewarding.

To help you steer your clients through the more complex areas of planning, our technical experts provide comprehensive insights on gifting in our key markets,and the role life insurance can play in effective wealth transfer strategies.

In the Case Study Insights section, we bring these planning opportunities to life, illustrating how an insurance solution can contribute to effective wealth transfer strategies.

Elsewhere, we keep you up to date with key fiscal changes in France, explore the impact of Inheritance and gift tax reductions announced in Spain and outline the evolving situation in Norway regarding tax rules for corporate policyholders.

As we explore the intricacies of gifting and wealth transfer in this edition, we aim to equip you with the knowledge and tools needed to approach these areas with confidence.

As always, our team is here to support you in delivering the best possible outcomes for your clients.

Aidan Golden
Head of Group Technical Services

 

PulseRegulation, Tax and ComplianceTechnical SpotlightCountry FocusCase Study InsightsUpcoming Events Download PDF

In this issue

Pulse

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

Regulation, Tax and Compliance
Technical Spotlight
Country Focus
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.

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

  • Final 2025 Law published on 28 December 2024 – it has confirmed provisions included in the initial draft.
  • It confirms the 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.
  • Utmost PanEurope currently working on implementing the new provisions.

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.
No updates as final Regulation was not issued by the end of 2024.

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.

January 2025

  • 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 1 January 2025, large companies (250+ employees) must track CSRD data for 2026 reporting.

France
2025 Budget Act No. 2025-127

Life insurance is safe and sound
Several fiscal adjustments, while life insurance maintains its favourable tax treatment.

14 February 2025

  • Introduction of a minimum 20% tax on high incomes.
  • Tightening of capital gains taxation for non-professional furnished rental properties (LMNP).
  • New tax framework for management packages
  • Indexation of the income tax scale.

EU
Omnibus Simplification Package published

Proposed Omnibus regulation to cut ‘red tape’.

26 February 2025

  • ‘Omnibus Simplification Package’ published.
  • Contains proposals to reduce CSRD and CSDDD burdens on firms and simplify obligations under the Taxonomy Regulation.
  • Proposals de-scope a number of firms from the CSRD reporting requirements altogether.
  • Package also contains proposals to postpone the reporting obligations for firms reporting for financial years 2025 and 2026 to prevent possible costs of reporting before being de-scoped.
  • Unclear when and what proposals will come into effect.

Belgium
New Law on capital gains tax on ‘financial assets’ held by Belgian residents

Question as to whether Branch 23 (unit-linked) insurance contracts will fall into the scope of the new Law.

31 December 2025

  • The new Belgian government agreement of January 2025 contains a paragraph expressing the intention to introduce as from the tax year 2026, a capital gains tax on ‘financial assets’ held by Belgian residents.
  • The government agreement contains no further details on this intended capital gains tax and it is not clarified what will fall into the scope of the definition of ‘financial assets’.
  • Impact will depend on the exact modalities of the Law.

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 1 January 2026.

EU
Artificial Intelligence (AI) Act

Majority of provisions in the Act to take effect.

2 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 2 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.

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.
  • Consultation paper released December 2024 on proposed targeted support reforms for pensions with comments by 13 February 2025.
  • Plan to consult on rules for better support for consumers in retail investments and pensions by end H1 2025.

UK
UK Finance Bill

UK Finance Bill has received Royal Assent, enshrining changes in UK tax law.

20 March 2025

  • Changes announced in the 2024 Autumn Budget, including the removal of the remittance basis of taxation from the new tax year, are now enshrined into UK tax law.

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.

6 April 2025

  • UK IHT moves from domiciled-based system to residence based system from 6 April 2025.
  • Excluded Property trust and UK Trust Protections removed from 6 April 2025 – property will be in scope for IHT based on a person’s long-term residence.
  • Remittance basis removed from 6 April – FIG regime introduced to allow arrives who have been non-resident for 10 consecutive years to benefit from four years of tax relief.

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
Regulatory regime for ESG ratings providers

HM Treasury currently finalising the scope of the regime.

2025

  • Regime expected to improve transparency and quality of ESG ratings for investments and other types of financial products.
  • Treasury published consultation response November 2024.
  • FCA expects to consult on proposed rules in 2025.

UK
Financial Conduct Authority Crypto roadmap

FCA expects all Policy Statements that form the new Crypto regime to be published in 2026.

2026

  • Roadmap 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.
  • DP24/4: Regulating cryptoassets – Admissions & Disclosures and Market Abuse Regime for Cryptoassets published 16 December 2024.
  • Discussion paper on Trading platforms, Intermediation, lending and staking rules and prudential considerations for cryptoasset exposures to be published Q1/Q2 2025.

UK
IHT on unused pensions savings

UK Government remain committed to including unused pensions savings in estates for IHT purposes.

April 2027

  • Autumn Budget announced unused pension savings may be included in people’s estates for IHT.
  • Despite industry pushback, the pensions minister has stated that there will be no change of approach from the government in this matter.

Norway
Proposal for a revision of tax rules applicable to corporate policyholders

If passed, will impact corporate clients holding policies as gains from shares within the policy will no longer be tax exempt at withdrawal.

1 January 2026

  • The proposal from the Ministry of Finance is looking at abolishing the tax exemption method currently applicable to the share portion of the policy. This only impacts corporate clients.
  • The changes are suggested to apply retroactively, as per 30 January 2025.
  • The proposal is currently under consultation until 30 April 2025.

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 1 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

Norway's Tax Rules for Corporate Policyholders Under Review

Laura Blomqvist
Senior Wealth Planner – Finland and Norway

On 30 January 2025, Norway’s Ministry of Finance unveiled a proposal that could reshape the landscape for corporate investments in unit-linked life insurance policies.

Laura Blomqvist explores the potential shift in tax rules, its implications for corporate policyholders, and what this means for the future of corporate tax planning in Norway.

Read the article

Finnish Government’s “Room for Growth Working Group” Publishes Report

Jari Vill
Tax and Legal Counsel Scandinavia

In autumn 2024, Finnish Prime Minister Petteri Orpo appointed the Room for Growth project to identify strategies for promoting sustainable economic growth in Finland.

Jari Vill, Tax and Legal Counsel – Scandinavia, provides an update on the expert working group’s final report, submitted on 28 February 2025.

Read the article

Technical Spotlight

Global Insights on Tax-Efficient Gifting

Europe

Inheritance and Gift Planning for Belgian and Luxembourg Residents

Nicolaas Vancrombrugge
Senior Wealth Planner – Belgium and Luxembourg

Navigating inheritance and gift tax planning can be complex, especially for wealthy residents of Belgium and Luxembourg. In this article, Nicolaas Vancrombrugge, Senior Wealth Planner – Belgium and Luxembourg, explores the intricacies of inheritance tax rates and the flexible legislation regarding gifts in both countries.

Discover how different gifting options, including bankable assets and insurance contracts, can help manage wealth transfer efficiently while maintaining control over donated assets.

Read the article

Strategic Gifting for French Expatriates: Maximising Tax Efficiency Before Returning to France

Benjamin Fiorino
Wealth Planner / Tax and Legal Counsel, France and Monaco

For expatriates planning to return to France, strategic gifting can play a crucial role in minimising tax liabilities.

This article explores the intricacies of French gift tax rules and offers practical advice on how to structure donations effectively before repatriation. By understanding the timing and legal considerations, families can optimise their wealth transfer strategies and ensure a smoother financial transition.

Read the article

UK

New UK IHT Rules: A Seismic Shift in How UK Expats Pass on Their Wealth

Glenn McIIroy
Technical Services Manager

As of 6 April 2025, UK inheritance tax (IHT) rules have undergone a significant transformation, shifting the focus from domicile to residency. This change presents advisers with fresh opportunities to assist UK expatriates in optimising their wealth succession and gifting strategies.

Glenn McIlroy, Technical Manager, explores the nuances of these new rules, offering insights on how they can influence your clients’ financial planning and help them maximise their assets.

Read the article

Maximising UK IHT Efficiency with an Insurance-Based Wealth Solution

Lana Jarvis
Senior Wealth Planner – UK and International

Estate and tax planning can be a complex balancing act, especially when it comes to transferring wealth efficiently while maintaining control over access.

In this insightful analysis, Lana Jarvis explores how an insurance solution with built-in restrictions can offer a robust solution for those concerned about premature access to funds or poor financial management by recipients.

Read the article

Asia

Transforming Estate Planning for China’s HNW Families with Life Insurance

Peter Tung
Tax and Legal Counsel – Asia

For high-net-worth (HNW) families in China, preserving wealth across generations requires precision, foresight, and tools that transcend borders.

Peter Tung, Tax and Legal Counsel – Asia, explains how life insurance, paired with cross-border strategies, becomes essential for efficient, dispute-free wealth transfer. Discover how you can harness its power to protect your client’s legacy.

Read the article

Singapore Beneficiary Nominations and Insurance-Based Wealth Solutions

Brendan Harper
Head of Asia and HNW Technical Services

Explore how a senior executive effectively manages his wealth and ensures seamless transfer to his heirs using Singapore beneficiary nominations and an insurance solution.

This case study highlights the flexibility, control and asset protection offered by these financial planning strategies.

Read the article

Country Focus

Madrid's Regional Prime Minister Announces Further Inheritance and Gift Tax Reductions

Nerea Llona
Tax and Legal Counsel – Spain and LatAm

Madrid’s regional Prime Minister recently announced the beginning of the legislative process to implement certain reductions and benefits related to Inheritance and Gift Tax (“IHGT”), which will allow for more succession planning opportunities in this highly tax-competitive Spanish region.

In this article, Nerea Llona, Tax and Legal Counsel – Spain and LatAm, examines the details of these proposed reforms, exploring their potential impact on wealth management and succession planning.

Read the article

2025 French Budget Act: Impacts on Wealth Management and Life Insurance

Krystel Gillard
Wealth Planner / Tax and Legal Counsel Francophone market

The 2025 French Budget Act brings significant tax changes for high earners, real estate investors, and wealth transfer strategies. New minimum taxes on high incomes, stricter capital gains taxation on non-professional rental properties, and revised tax treatment for management packages are reshaping financial planning in France.

Amid rising taxation, life insurance remains a key tool for tax efficiency, investment flexibility, and estate planning. Krystel Gillard explores how these new regulations impact wealth structuring in France.

Read the article

French Tax Code: Impacts of Article 774 bis on Life Insurance and Capitalisation Contracts

Nicolas Morhun
Senior Wealth Planning, Associate Director – France

Repartition of rights has long been a cornerstone of wealth structuring in France. With the introduction of Article 774 bis of the French Tax Code, recent clarifications from the French tax administration underscore the enhanced benefits of insurance solutions in managing these rights.

In this article, Nicolas Morhun, Senior Wealth Planner, explores how these changes impact life insurance and capitalisation contracts, offering valuable insights for those looking to optimise their wealth planning strategies.

Read the article

Case Study Insights

Nicolaas Vancrombrugge
Senior Wealth Planner – Belgium and Luxembourg

Efficient Inheritance Planning and Wealth Management for a Belgian Family

This case study examines the inheritance planning and wealth management strategy for a middle-aged couple in Belgium. a €4 million investment, they aim to structure their wealth efficiently, retain control over their assets, provide for their three children, and implement a unified family investment strategy. The tailored solution and its benefits are outlined below.

Read the Case Study

Benjamin Fiorino
Wealth Planner / Tax and Legal Counsel, France and Monaco

A French Expatriate Family in Dubai

For expatriates planning to return to France, strategic gifting can play a crucial role in minimising tax liabilities.

This case study explores the options available to a French expatriate family residing in Dubai. As they plan to return to France, the couple aims to efficiently transfer €8 million to their children while minimising tax liabilities

Read the Case Study

Lana Jarvis
Senior Wealth Planner – UK and International

Effective UK Inheritance Tax Planning

Learn how a client used an insurance-based wealth solution with built-in restrictions to efficiently manage UK inheritance tax planning, ensuring wealth is passed on to future generations while maintaining control over access.

 

Read the Case Study

Brendan Harper
Head of Asia and HNW Technical Services

Singapore Beneficiary Nominations and Insurance-Based Wealth Solutions

Explore how a senior executive effectively manages his wealth and ensures seamless transfer to his heirs using Singapore beneficiary nominations and an insurance solution.

This case study highlights the flexibility, control and asset protection offered by these financial planning strategies.

Read the Case Study

Nerea Llona
Tax and Legal Counsel – Spain and LatAm

Gifting with Control in Spain

This case study explores how an insurance-based wealth solution can be used in Spain to facilitate gifting with control to the next generation in a tax-efficient manner.

By examining the specific case of a 70-year-old widow in Madrid, we highlight the benefits and strategic advantages of using these insurance solutions for wealth transfer and succession planning.

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

UK

Concerned about the increase in CGT rates?

Join Steve Sayer, Technical Sales Manager, to learn how wrapped investments can mitigate capital gains tax, ease administration and offer flexibility. Hosted by Marc Acheson, Global Wealth Specialist with case studies and an interactive Q&A session featuring Simon Martin, Head of UK Technical Services.

23 April 2026, 9.30am BST

Find out more

LatAm

International Private Client Conference Miami 2025

A premier event for multigenerational businesses, exploring global strategies in governance and wealth planning with top industry leaders.

24 April 2025, 8.30 AM – 7.30 PM EDT

Find out more

France

CNCGP MidSommar Paris

12 June 2025

Find out more

France

La Rencontre Occur Paris – 5ème édition

24 June 2025

Find out more

France

Sommet Patrimoine et performance

The summit will provide an opportunity for industry professionals to gather and reflect on current issues and best practices, while providing public recognition for the initiatives and innovations of passionate leaders and entrepreneurs.

09 July 2025

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.