Milestone is a boutique international tax practice established in Mayfair, London.


Flexible investments for non-domiciled residents

The Client

Swiss Private Bank

The Problem

Hot on the heels of changes to the ‘UK resident non-domiciled’ rules, this bank wanted to know whether their non-domiciled clients could use a particular investment product (essentially a ‘tweaked’ plain vanilla bond) to manage their tax position.

The Solution

We were able to structure the investment in line with the existing rules, whilst giving investors the additional flexibility of selecting the remittance basis with the funding support, to meet the non-remittance based charge.