Personal Tax Strategy &
International Income Optimisation

1. Foreign Income & the FIG Regime — What Actually Applies to You

Clarification: The 4-Year FIG Regime & Your Eligibility

The UK introduced the Foreign Income and Gains (FIG) regime on 6 April 2025, replacing the historic non-dom remittance basis. Under this new regime, qualifying individuals can claim relief from UK tax on their foreign income and gains for up to four consecutive tax years. On the surface, this sounds like it could be extremely beneficial for someone in your position — however, the eligibility criteria are strict and, based on what we know of your circumstances, you are unlikely to qualify.

To be eligible, you must be a "qualifying new resident", which means you must have been non-UK tax resident for at least 10 consecutive tax years immediately before the tax year in which you are claiming the relief. Since you are currently employed in the UK and have been UK resident (presumably for several years at least), you do not meet this 10-year non-residence requirement.

Your Foreign Income — How It Is Taxed

As a UK tax resident, you are required to declare and pay UK tax on your worldwide income, which includes all income from India, Singapore, the European country, and of course your UK employment. This applies regardless of whether the income stays in foreign bank accounts or is brought to the UK. The old rules where keeping money offshore could defer UK tax (the remittance basis) were abolished on 5 April 2025.

However, the fact that you are being taxed in multiple countries means you should be entitled to Double Taxation Relief (DTR) to prevent being taxed twice on the same income. The UK has extensive double taxation agreements with India and Singapore, among others. Under these treaties, where tax has been paid abroad on the same income, you can generally claim a credit against your UK tax liability for the foreign tax already paid. This is claimed through your Self Assessment tax return.

Income From India

India taxes residents on worldwide income and non-residents on Indian-sourced income. The UK-India Double Taxation Avoidance Agreement (DTAA) provides relief mechanisms depending on the type of income. Interest income from Indian bank accounts is generally subject to a withholding tax in India (typically 10-15% under the treaty for interest), and this tax can be offset against your UK tax liability. Rental income from Indian property would be taxable in both jurisdictions, but again with DTR available. Capital gains on Indian assets have specific treaty provisions — notably, India retains the right to tax capital gains on shares in some circumstances under the treaty, but you can claim credit in the UK.

It is essential that you file your Indian tax returns correctly and obtain Tax Residency Certificates (TRCs) from the UK to claim treaty benefits in India, and retain Indian tax documentation to claim DTR in the UK.

Income From Singapore

Singapore operates a territorial tax system, meaning it generally taxes only income sourced in or remitted to Singapore. Singapore's personal tax rates are also notably lower than the UK's (topping out at 24% for income above SGD 1,000,000). The UK-Singapore double tax treaty covers employment income, interest, dividends, and royalties with specific provisions for each.

You mentioned you will engage a local advisor in Singapore for your Singapore tax return, which is sensible. We would recommend ensuring that your Singapore advisor coordinates with your UK advisor to ensure that the income is consistently classified across both jurisdictions and that DTR is maximised. If you would like, we can liaise with your Singapore accountant directly to ensure alignment — this is something we can offer as part of our service.

Income From Europe

Without knowing the specific European country, we cannot provide detailed treaty analysis here. However, most EU and European countries have comprehensive double tax treaties with the UK. The general principle remains: income is reportable in the UK on the arising basis, with credit given for foreign tax paid. Once you confirm the country, we can provide a specific breakdown of the treaty provisions and optimal reporting strategy for that jurisdiction.

2. Dubai Relocation — Tax Implications, Planning & Timing Strategy

The Opportunity

The UAE does not levy personal income tax. If you become non-UK tax resident and take up employment in Dubai, your Dubai employment income will be completely free of both UAE and UK income tax. This represents a potentially enormous tax saving given your income level. However, getting this right requires meticulous planning, because HMRC scrutinises Dubai relocations closely — it is one of the most common scenarios they investigate.

Your Timeline: The 12-Month Notice Period

The Dubai job offer starts March 2027, and you need to give your current UK employer 12 months' notice. This means you would likely need to hand in your notice by approximately March 2026 (i.e., now or very shortly). The critical question for tax purposes is: in which tax year does your departure fall?

If you leave the UK and commence Dubai employment in March 2027, this falls in the 2026/27 tax year (6 April 2026 to 5 April 2027). You would have been UK resident for most of that tax year before departing. This is where Split Year Treatment becomes critical.

Split Year Treatment — Case 1 Analysis

Under the Statutory Residence Test (SRT), if you leave the UK partway through a tax year to start full-time work overseas, you may qualify for Split Year Treatment under Case 1. This would mean the 2026/27 tax year is split into two parts: a UK part (6 April 2026 until your departure date) where you are taxed as UK resident on worldwide income, and an overseas part (from your departure date to 5 April 2027) where you are treated as non-resident and only UK-sourced income is taxable.

To qualify under Case 1 (paragraph 44, Schedule 45, Finance Act 2013), several conditions must all be met simultaneously. First, you must start full-time work overseas (averaging 35+ hours per week) and have no significant UK work after your departure. Second, during the overseas part of the departure year (March to 5 April 2027), you must do no more than a pro-rated permitted number of UK work days (roughly 2 days for a March departure) and spend no more than a pro-rated permitted number of days in the UK (roughly 7 days for a March departure). These limits are calculated by reducing 30 and 90 respectively, based on how many whole months of the tax year have passed before departure. Third, and critically, you must be non-UK resident for the following tax year (2027/28) — specifically because you meet the third automatic overseas test, which requires fewer than 91 UK days and fewer than 31 UK work days in that year. Your planned 90 UK days with 30 work days in 2027/28 sits at the absolute razor edge of this test. One miscounted day, one delayed flight, one unexpected overnight stay, and the test fails — which retroactively collapses the Case 1 claim for the departure year, meaning you would be taxed as UK resident on worldwide income for the entire 2026/27 tax year, including your Dubai salary from March onwards.

The Statutory Residence Test — Ongoing Compliance

Once you leave the UK, you need to ensure you remain non-UK tax resident under the SRT for each subsequent tax year. The key tests to be aware of are: the Automatic Overseas Test (you will qualify if you work full-time overseas and spend fewer than 91 days in the UK, with fewer than 31 of those being working days); and the Sufficient Ties Test (the more ties you retain to the UK — family, accommodation, substantive work, 90-day presence in prior years — the fewer days you can spend in the UK before being deemed resident).

At exactly 90 UK days, the third automatic overseas test is technically borderline since 90 is less than 91. But this margin is impossibly thin — any miscounted day pushes you to 91 or above, at which point the automatic test fails and the sufficient ties test applies. Under the SRT table, a leaver spending 46–90 UK days with 3 ties is classified as UK resident. Your planned 90 days (30 working days plus 60 weekend days) falls squarely within this bracket. Operating at this margin is not tax planning — it is gambling with your entire UK tax position.

Given that you will retain significant UK ties (family, accommodation potentially, 90-day presence in prior years), we strongly recommend keeping your UK visits well below 90 days per year — ideally below 45 days to provide a comfortable margin. We would prepare a detailed day-count budget for you based on your specific ties.

The Temporary Non-Residence Trap

This is critically important. If you have been UK resident for at least 4 out of the 7 tax years before your departure, and you return to the UK within 5 years, the Temporary Non-Residence (TNR) rules may apply. Under TNR, certain income and capital gains that arose while you were non-resident can be taxed when you return. This specifically includes capital gains on assets held before departure, certain dividend income, and pension withdrawals.

Employment income earned overseas is generally not caught by TNR rules, so your Dubai salary would remain protected. However, if you plan to sell any significant assets (shares, property, investments) while in Dubai, you should either plan to stay non-resident for more than 5 full tax years, or ensure those disposals are structured to fall outside the TNR scope.

UK-UAE Double Taxation Agreement

The UK and UAE have a double tax treaty that covers employment income, dividends, interest, royalties, and capital gains. Since the UAE does not charge personal income tax, the treaty primarily benefits you by confirming that your Dubai employment income is not taxable in the UK once you are non-UK resident. The treaty also provides useful protections for other income types — for example, private pensions paid from the UK to a UAE resident are exempt from UK tax under the treaty (though you would need to complete the relevant HMRC forms).

3. International Inheritance — Asset Sale & UK Tax Impact

The New Residence-Based IHT Rules

From 6 April 2025, the UK moved from a domicile-based to a residence-based system for Inheritance Tax. Under the new rules, if you have been UK tax resident for at least 10 out of the previous 20 tax years, you are classified as a "Long-Term Resident" (LTR) and your worldwide assets fall within the scope of UK IHT. This is a significant change from the old system, where your domicile status determined IHT liability.

Your IHT position is actually very favourable. With only 5–6 years of UK residence, you fall well short of the 10-year Long-Term Resident threshold. This means your non-UK assets are already outside the scope of UK inheritance tax, even while you are still UK resident. There is no IHT tail period to worry about because the tail only applies to individuals who were Long-Term Residents when they left. Your UK property remains within IHT scope regardless of residence, but your international holdings — India, Singapore, Luxembourg — are entirely outside it. This is a significantly better position than many international professionals in your situation.

Receiving Inherited Assets — The Tax Position

First, the good news: receiving an inheritance is not in itself a taxable event in the UK. There is no UK income tax or capital gains tax on the act of receiving inherited money or assets. Any IHT liability falls on the estate of the deceased, not on you as the beneficiary.

However, what happens after you receive the assets is where tax complications arise. Specifically:

If you sell inherited assets: Capital Gains Tax (CGT) may apply on any increase in value from the date of death to the date of sale. The acquisition cost for CGT purposes is the market value at the date of death (known as the "probate value"), not the original purchase price paid by the deceased. For overseas assets, the gain must be calculated in GBP using exchange rates at both the date of death and the date of sale.

If the assets generate income: Any rental income, interest, or dividends from inherited overseas assets are taxable in the UK as your income from the date you receive them.

Double Taxation on Inherited Assets

If the inherited assets are located in a country that also charges inheritance tax or capital gains tax on disposal, you may face a double tax charge. The UK has IHT double tax treaties with several countries including India, France, Netherlands, Sweden, Switzerland, Ireland, Italy, and others. Where a treaty exists, relief is generally available to prevent double taxation. Where no treaty exists, you may be able to claim Unilateral Relief from HMRC for foreign tax paid.

We would need to know the specific countries where the inherited assets are located to provide detailed guidance on the treaty provisions and optimal disposal strategy for each asset.

4. Overall Income Optimisation — Structuring $10M+ Income

Understanding Your Tax Exposure

With total taxable income of approximately $10 million USD (roughly £7.9 million at current exchange rates), you are firmly in the Additional Rate tax band (45% on income above £125,140 for 2025/26). When you factor in National Insurance contributions (if applicable to your employment type) and the loss of the personal allowance (which is fully withdrawn for income above £125,140), your effective marginal tax rate on UK-source income is approximately 47-48%.

At this income level, even small percentage improvements in tax efficiency can translate to tens or hundreds of thousands of pounds in savings. Here are the key strategies available:

Pension Contributions

Pension contributions remain one of the most tax-efficient vehicles available. As an additional rate taxpayer, you receive 45% tax relief on pension contributions. The standard Annual Allowance is £60,000 per year (for 2025/26), however this is subject to tapering for high earners. At your income level (~$10M), your adjusted income massively exceeds £360,000, so the tapered annual allowance is the minimum: £10,000. Any unused allowance from the three preceding years can be carried forward. The three years available for carry forward from 2026/27 are 2023/24, 2024/25, and 2025/26 — in each of those years, at your income level, the tapered allowance would also be £10,000. If you made no pension contributions in those years (and your current pension pot of £30,000 suggests very limited contributions to date), unused carry forward is approximately £30,000 (£10,000 from each prior year). That gives a total maximum contribution for 2026/27 of £40,000 — your £10,000 current year allowance plus £30,000 carry forward — attracting 45% tax relief. The net cost would be approximately £22,000 for £40,000 of pension savings, which is still a meaningful saving. The actual carry forward depends on your adjusted income in each prior year — if there were years where your UK-reportable income was lower, the tapered allowance may have been higher than £10,000. This is something we would need to verify with your existing accountant's records before confirming exact figures.

Tax-Efficient Investment Structures

Consider maximising use of ISAs (£20,000 annual allowance per person), Venture Capital Trusts (VCTs) and Enterprise Investment Schemes (EIS) which offer up to 30% income tax relief on investments, and Seed Enterprise Investment Schemes (SEIS) offering 50% relief. At your income level, the absolute amounts are relatively small compared to total income, but they represent guaranteed, risk-adjusted returns and should not be overlooked.

Charitable Giving

Gift Aid donations are particularly efficient for additional rate taxpayers. A £10,000 donation to a registered charity costs you only £5,500 after tax relief (the charity claims 25% basic rate, and you claim a further 25% through your tax return). If philanthropy is something you value, this is an extremely efficient way to support causes while reducing your overall tax bill.

The Dubai Factor

The single most impactful tax optimisation available to you is the Dubai relocation itself. Moving to a zero-income-tax jurisdiction could save you in the region of £3-4 million per year in UK income tax (rough estimate based on $10M income). This dwarfs all other optimisation strategies combined. However, it must be executed correctly — the consequences of getting the residence status wrong at this income level would be catastrophic.

5. Singapore Tax Considerations & Cross-Border Planning

Overview of Your Singapore Position

You mentioned that you receive income from Singapore and will engage a local advisor there for Singapore tax filing. This is the right approach. Singapore's tax system is territorial — it generally taxes income that is sourced in or remitted to Singapore. Tax rates are progressive, with a top rate of 24% on income exceeding SGD 1,000,000 (approximately £590,000).

Without knowing the exact nature of your Singapore income (employment, investment, business profits, rental, etc.), we can provide the following general guidance:

Employment income: If you are employed by a Singapore entity but working from the UK, the income may be taxable in Singapore (depending on where the duties are performed) and will definitely be taxable in the UK. The UK-Singapore DTA provides relief to prevent double taxation, generally giving the primary taxing right to the country where the employment duties are performed.

Investment income (dividends, interest): Singapore does not tax dividend income received by individuals. Interest income may be taxed depending on the source. The UK will tax you on all such income, but credit will be given for any Singapore tax paid.

Rental income from Singapore property: Taxable in both Singapore and the UK, with DTR available in the UK for Singapore tax paid.

Impact of Dubai Move on Singapore Income

Once you relocate to Dubai and become non-UK resident, your Singapore income will no longer be reportable or taxable in the UK (unless it is UK-sourced). You would then need to consider the Singapore-UAE tax position instead. Singapore does not tax overseas employment income or most foreign-sourced income unless it is remitted to Singapore. This could create a very favourable position where your Singapore investment income is taxed only in Singapore (at potentially lower rates) and not taxed at all in the UK or UAE.

6. Making Tax Digital (MTD), Compliance & Next Steps

Does MTD Apply to You?

Making Tax Digital for Income Tax Self-Assessment (MTD ITSA) is being rolled out from 6 April 2026. However, it applies specifically to individuals with gross income from self-employment and/or property exceeding £50,000 (for the first phase from April 2026, reducing to £30,000 from April 2027 and £20,000 from April 2028).

Based on what you have told us, your income is primarily from employment (UK and potentially Dubai) and investment/foreign income. MTD ITSA does not currently apply to employment income, investment income, foreign employment income, dividends, or bank interest. It only applies to self-employment (sole trader) and property rental income.

Your 2025/26 Tax Return

You mentioned that your current accountant will complete your 2025/26 tax return (due by 31 January 2027). Given the complexity of your affairs — particularly the foreign income from multiple jurisdictions, the need to accurately claim double taxation relief, and the potential interaction with the new FIG regime rules — we would strongly recommend that you ensure your current accountant has specific expertise in international tax matters. If there is any doubt, it may be worth having the return reviewed by a specialist before submission.

Transition to LOYALS for 2026/27 Onwards

For the 2026/27 tax year — which is the year in which your potential Dubai move would occur — the complexity increases dramatically. You would need to deal with Split Year Treatment claims, SA109 Residence supplementary pages, cessation of UK employment, commencement of overseas employment, potential re-classification of foreign income sources, and possible Non-Resident Self Assessment obligations going forward.

This is exactly the kind of complex, internationally-flavoured tax return that LOYALS specialises in. Our fee for preparing your 2026/27 Self Assessment tax return (including all supplementary pages, residence analysis, DTR claims, and HMRC correspondence) would be £600.

Recommended Action Plan & Timeline

Immediate (March 2026): Confirm whether you will accept the Dubai offer. If yes, submit your notice to your current employer. Begin documenting your UK ties for the Statutory Residence Test analysis. Contact us to begin detailed planning.

Before 5 April 2026: Review whether any capital gains should be realised before the end of the current tax year (to use your CGT Annual Exempt Amount). Consider making pension contributions to maximise relief while still a UK taxpayer.

April 2026 – Departure: Ensure your employer is aware of your leaving date. Begin notifying HMRC of your plans to leave the UK. Arrange for your UK property situation (sell, let, or retain — each has different tax implications). Keep a detailed log of UK days from this point forward.

On Departure: Complete form P85 (Leaving the UK) and submit to HMRC. Ensure your UK home is disposed of or formally let. Set up UAE tax residency documentation. Begin your Dubai employment.

Post-Departure (2027): File your 2026/27 UK tax return with Split Year Treatment claim. Keep meticulous records of UK visits. Consider timing of inherited asset disposals. Continue annual UK filing as required for any remaining UK income sources.