Citywealth Quick Insight Series on Tax Trends – Anna Warren, Bentley Reid

Date: 05 Aug 2026

Karen Jones

This week’s Citywealth Quick Insight Series on Tax Trends is dedicated to Anna Warren, Tax Director at Bentley Reid.

How would you summarize the current global tax environment for UHNW individuals and families? Are there particular jurisdictions that are becoming more (or less) attractive?

There are still plenty of options for UHNW individuals and families.  I would say the following in terms of which jurisdictions are becoming more (or less) attractive:

Less attractive:  The UK, which was the model of attractiveness for UHNW for years has obviously had a fall from grace, with the replacement of the narrow 4-year FIG regime and IHT based on residence rather than domicile (particularly with the potential for a long-tail) has meant that the UK has had one of the largest recorded outflow of millionaires from any country in a single year.

Portugal also changed its ‘non-dom’ regime, such that individuals looking to move there now have to qualify based on being a highly skilled worked in order for their foreign income to be exempt as it was.

More attractive:  With the non-dom exodus from the UK, the most common countries were UHNW moved were Italy, Switzerland, where they each have a flat-tax/lump sum regime.  Some also moved to Dubai, but given the instability in the region, this has become less attractive, which in turn has led more to considering SE Asian countries like Singapore/Hong Kong.

What recent tax policy changes in key regions—such as the U.S., UK, EU, or Asia—do you believe have the most significant implications for global wealth structuring?

I think the UK’s ending of the non-dom regime has had the most significant impact, because it had a high concentration of global UNHW individuals.

China’s recent announcement on the taxation of offshore trusts will also have a big impact on structuring in Hong Kong.

What are the emerging cross-border tax challenges facing wealthy international families today?

We see challenges with family trusts having beneficiaries in multiple jurisdictions, with each jurisdiction potentially asserting a taxing right over the same income and treaty relief not always keeping pace.  This can be especially prevalent with trusts, especially if certain beneficiaries are resident in civil law jurisdictions (such as Spain or France), which don’t easily recognise trusts.

How are advisors helping clients prepare for increased transparency, disclosure rules (like CRS and FATCA), and information-sharing regimes?

To be honest, I think these have been around for a long time now that I don’t get asked about them.  Most clients have accepted this for a long-time.

In what ways are philanthropic structures and charitable giving being shaped by evolving tax legislation and public policy?

I haven’t seen much change in this area.

What role do tax-efficient investments (e.g., private placement life insurance, real estate, etc.) play in your clients’ strategies, and are these evolving?

I think that UK real estate has become much less appealing as an investment and also considered much higher risk.  With the myriad of taxes that face individuals buying UK property, and the exodus of UNHW from the region, there is much less appetite to buy there, unless they see it as their long-term home.

Private placement life insurance has become more popular for UNHW, due to the ability for tax-deferral.  They come with restrictions and in the UK are only appealing for liquid investments.

How is succession and estate planning being impacted by new inheritance, wealth, or exit tax proposals globally?

There used to be more certainty in the planning that you would provide.  Given the changes and potential for people to be more mobile, then I think less is most often more when it comes to longer term plans.  For example in the UK, I see more people looking to insurance to cover potential IHT, whilst waiting for more stability in the tax system to understand their position.

Are you seeing increased interest in alternative jurisdictions, citizenship or residency-by-investment programs due to tax considerations?

For me, yes that would be from the changes to the non-dom regime as explained above.  I would note that I have some clients who are still within the first 10 years of UK residency and are considering moving before they reach that milestone in order to avoid the IHT, whereas before they may have stayed much longer term.

How are tax authorities using digital tools, AI, and data analytics to enhance enforcement—and how should advisors respond?

My only experience is with HMRC, where everything currently remains quite antiquated in my experience.  However, they are obviously looking to improve this point and I think it will mean they can be more targeted in their enquiries.  For UHNW individuals for a long-time now they are often the ones who have the advisers to get their tax affairs correct.  Where I see the issues, is the less wealthy individuals who think they can use AI to obtain tax advice (which isn’t quite there yet!)  In addition, these people will often do tax returns themselves, not know they should have filed etc. and they are receiving prompt letters from HMRC (due to CRS etc) that mean they are considering and rectifying their affairs for the first time.

Looking forward, what are your top predictions or concerns about the future direction of global tax policy for UHNW clients over the next 12–24 months?

I think in the UK we will see a number of changes to tax policy, depending on what they are, will depend on whether the UK can become more attractive again.  The worst thing that can happen is constant changes, so I would certainly like to see a period of stability.

For a while now I think UHNW individuals have been conscious of the fact that they have to be aware of CRS etc. and keep on top of advice. 

I think we could see more experiments with wealth taxes and exit taxes, which I would predict would shift more UHNW individuals into the countries that don’t have them, so Italy/Switzerland will be the beneficiaries.

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