For the multi-jurisdictional family office, the regulatory environment of 2026 demands a complete departure from static tax planning. Landmark legislative shifts — most notably the complete abolition of the long-standing UK "non-dom" regime and its replacement with the residence-based Foreign Income and Gains (FIG) system — have sent shockwaves through the wealth management sector. Dual-citizens and global families can no longer rely on historic, passive offshore structures. To insulate multi-generational wealth from aggressive fiscal overhauls, families must proactively redesign their structures across key international jurisdictions, transforming their estate planning into a dynamic, highly responsive chessboard.
The Death of Domicile and the Rise of Residency
For decades, the concept of "domicile" served as the foundation of international tax planning, particularly for wealthy individuals residing in the UK who kept their foreign assets entirely insulated from domestic taxation. The implementation of the new FIG framework has permanently dismantled this shelter, replacing it with a strict residency-based model.
Under the updated rules, individuals who move to the UK after ten consecutive years of non-residence are granted a strict four-year window of 100% tax relief on foreign income and gains. However, once that initial period expires, global income and assets are subject to standard domestic tax rates — regardless of where the wealth was generated or where the principal originally considers "home".
This shift has profound implications for estate and succession planning. Domicile has similarly been removed as a factor for Inheritance Tax (IHT). Instead, long-term residency now dictates global IHT exposure, meaning that the worldwide assets of long-term residents — including those wrapped in historic, offshore settlor-interested trust structures — face full exposure to domestic estate taxes upon transfer or death.
Navigating Jurisdictional Alternatives: Switzerland and the Lump-Sum Model
As traditional tax havens face relentless compliance pressures under international transparency mandates, forward-thinking family offices are executing strategic geographic migrations. Switzerland has emerged as a premier destination for families seeking a stable, predictable, and legally secure alternative.
For non-Swiss nationals who do not engage in local gainful employment, several cantons offer the highly attractive "lump-sum" (or forfait) taxation regime. Rather than taxing an individual's actual global income and wealth, the lump-sum system calculates tax based on the taxpayer's lifestyle and living expenses in Switzerland — such as the rental value of their primary residence.
Depending on the chosen canton, this allows high-net-worth families to establish a stable, lifelong tax liability that is completely decoupled from their global investment returns. Furthermore, many Swiss cantons completely exempt transfers to spouses and direct descendants from gift and inheritance taxes, providing an exceptionally secure environment for preserving family legacies.
Restructuring for Long-Term Resilience
To adapt to this new era of fiscal transparency, dual-citizens and global allocators must systematically audit and restructure their holdings:
De-risking Trust Structures: Transitioning away from historic settlor-interested trusts which are no longer shielded from domestic tax codes, and exploring robust, irrevocable structures that align with current international regulations.
Utilising Repatriation Facilities: For families with historic, untaxed foreign income and gains, capitalising on temporary repatriation windows to remit foreign capital at highly concessionary tax rates.
Dynamic Residency Management: Carefully monitoring physical presence and day-counts across multiple jurisdictions to prevent accidentally triggering long-term tax residency in high-tax territories.
By moving away from outdated, passive structures and actively managing their tax footprint across multiple sovereign borders, global families can confidently protect their assets, maintain compliance, and secure their cross-border wealth for the next generation.
APX Intelligence Desk publishes proprietary analysis for verified members of the APX private network. This briefing is for informational purposes only and does not constitute financial, legal, or investment advice.
