UK Exit Plan · Move Scenario
Leaving the UK well: UAE, Monaco or Portugal
Sample client: fictional, married founder, two children, UK Ltd, GBP 6m net worth, considering UAE, Monaco and Portugal.
- Household
- Married, two children under 18, all moving together
- Residence
- UK resident for 20 of the last 20 tax years
- Company
- Sole owner of a UK trading Ltd; a sale is possible within three years
- Property
- Family home to be sold; one London flat to be kept and let
- Pension
- UK personal pension, not yet drawn
- Plans
- Leave early in the 2027/28 tax year; around 40 UK days a year after that; no plan to return
Section 1
Summary
For this family the United Arab Emirates is the strongest fit: 0% on dividends, 0% on capital gains and none for inheritance, a UK tax treaty (Yes (2016 convention)), and a residence route the family home itself can provide. Monaco offers the same zero on investment income inside Europe, but has no double tax treaty with the UK and a far higher cost of living. Portugal is the outlier: without the IFICI regime, which a founder selling up would not normally qualify for, dividends are taxed at 28% and gains at 28%.
The move only works if the UK side is clean. On the answers above the client scores 48/100 (Gaps to close) on the Latitax Exit Readiness check. The biggest single risk is not the destination but the UK: with 20 years of UK residence, the worldwide estate stays inside UK inheritance tax for 10 years after leaving, and a company sale made while away comes back into UK tax if the family returns within five years.
Section 2
The shortlist
The three countries the client asked about, each with the route they would use. Minimum stay is what keeps the visa, not the day count that makes you tax resident.
| Destination | Route and cost | Minimum stay | Dividends | Gains | Inheritance |
|---|---|---|---|---|---|
| United Arab Emirates Prime | Golden Visa - real estate investor From USD 545,000 | None stated | 0% | 0% | None |
| Monaco Prime | Residence permit (carte de séjour) for self-sufficient persons No fixed investment | None stated | 0% | 0% | 0% to children and spouses |
| Portugal Situational | Golden Visa (investment fund) From USD 575,000 | 7 days a year | 28% | 28% | 0% for children |
- United Arab EmiratesPrime
- Route
- Golden Visa - real estate investor, from USD 545,000
- Minimum stay
- None stated
- Dividends
- 0%
- Gains
- 0%
- Inheritance
- None
- MonacoPrime
- Route
- Residence permit (carte de séjour) for self-sufficient persons
- Minimum stay
- None stated
- Dividends
- 0%
- Gains
- 0%
- Inheritance
- 0% to children and spouses
- PortugalSituational
- Route
- Golden Visa (investment fund), from USD 575,000
- Minimum stay
- 7 days a year
- Dividends
- 28%
- Gains
- 28%
- Inheritance
- 0% for children
Sources and verification status for every figure are in section 3.
Section 3
Each option in detail
United Arab Emirates
PrimeNo personal income, capital gains or inheritance tax, a treaty with the UK and a golden visa within reach.
Approx. flight time from London: about 7 h to Dubai
How the client would be taxed there
- Tax system
- No personal income taxVerifiedUAE Federal Tax Authority - Taxation of Natural Persons under the Corporate Tax Law (and Cabinet Decision No. 49 of 2023) · checked 2026-09-29
- Dividends
- 0%VerifiedUAE Federal Tax Authority - Taxation of Natural Persons under the Corporate Tax Law (and Cabinet Decision No. 49 of 2023) · checked 2026-09-29
- Capital gains
- 0%SecondaryPwC Worldwide Tax Summaries - UAE, Individual, Other taxes · checked 2026-09-29
- Income tax, top rate
- 0%VerifiedUAE Federal Tax Authority - Taxation of Natural Persons under the Corporate Tax Law (and Cabinet Decision No. 49 of 2023) · checked 2026-09-29
- Inheritance
- NoneSecondaryPwC Worldwide Tax Summaries - UAE, Individual, Other taxes · checked 2026-09-29
- Wealth tax
- NoneSecondaryPwC Worldwide Tax Summaries - UAE, Individual, Other taxes · checked 2026-09-29
- Becoming tax resident
- 183 days, or 90 days with residence visa plus home or jobVerifiedCabinet Decision No. 85 of 2022 on Tax Residency (FTA unofficial translation) · checked 2026-09-29
- UK tax treaty
- Yes (2016 convention)VerifiedGOV.UK - United Arab Emirates: tax treaties · checked 2026-09-29
The residence route
A family home bought in Dubai doubles as the residence route.
10-year renewable self-sponsored residence for owning property worth AED 2,000,000 (~USD 545,000) or more; bank-financed and approved off-plan purchases qualify. Health insurance required. Not bound by the usual six-months-outside rule.
Investment from USD 545,000 · Minimum stay: none stated
Federal Authority for Identity, Citizenship, Customs and Port Security (ICP) - Golden Residency Guide · checked 2026-09-29Regimes to know about
- Qualifying Free Zone Person (0% corporate tax)Verified
A free-zone company that meets the conditions pays 0% on qualifying income (broadly, trade with other free-zone persons and specified qualifying activities) and 9% on everything else, with no AED 375,000 0% band on the non-qualifying part.
UAE Federal Tax Authority - Basic Tax Information Bulletin: Free Zone Person (Corporate Tax) · checked 2026-09-29 - Small Business ReliefVerified
UAE-resident businesses with revenue of AED 3,000,000 or less can elect to be treated as having no taxable income.
UAE Federal Tax Authority - Small Business Relief Corporate Tax Guide · checked 2026-09-29
Watch-outs for this client
- The UK Statutory Residence Test decides whether you have left, not your UAE visa: count UK days and ties, and remember temporary non-residence (under five full tax years away) can bring gains and some income back into UK tax.
- A company is taxed at 9% above AED 375,000 unless it is a Qualifying Free Zone Person; the free-zone 0% is lost for five years if the conditions slip.
- A UK-managed UAE company can be UK tax resident under central management and control, and UK CFC rules may apply if UK residents control it.
Monaco
PrimeNo personal income tax for non-French residents and no wealth tax, in the heart of Europe.
Approx. flight time from London: about 2 h to Nice, then about 30 minutes by road
How the client would be taxed there
- Tax system
- No personal income taxVerifiedMonServicePublic (Government of Monaco) - Inheritance tax and income tax information · checked 2026-09-29
- Dividends
- 0%VerifiedMonServicePublic (Government of Monaco) - Inheritance tax and income tax information · checked 2026-09-29
- Capital gains
- 0%VerifiedMonServicePublic (Government of Monaco) - Inheritance tax and income tax information · checked 2026-09-29
- Income tax, top rate
- 0%VerifiedMonServicePublic (Government of Monaco) - Inheritance tax and income tax information · checked 2026-09-29
- Inheritance
- 0% to children and spousesVerifiedMonServicePublic (Government of Monaco) - Inheritance tax and income tax information · checked 2026-09-29
- Wealth tax
- NoneUnverifiedMonServicePublic (Government of Monaco) - Inheritance tax and income tax information · checked 2026-09-29
- Becoming tax resident
- Residence permit plus genuine establishmentVerifiedMonServicePublic (Government of Monaco) - Inheritance tax and income tax information · checked 2026-09-29
- UK tax treaty
- No double tax treatyVerifiedGOV.UK - Monaco: tax treaties · checked 2026-09-29
The residence route
Residence for a self-sufficient person with a Monaco home.
Needs a Monaco home (deed, registered lease or free-accommodation certificate), a bank reference from a Monaco bank in the approved format confirming sufficient funds, a clean record and an interview. The state sets no minimum; the sum 'judged sufficient depends on the banking establishment'. Market sources commonly cite a deposit around EUR 500,000 (~USD 575,000), which is not an official figure. Issuance fee EUR 80; first card valid 1 year. Citizenship by naturalisation is exceptional, so treat it as not available.
No fixed investment · Minimum stay: none stated
MonServicePublic (Government of Monaco) - How to apply for a residence permit · checked 2026-09-29Watch-outs for this client
- French nationals who moved to Monaco are taxed in France as if still resident (Article 7 of the 1963 convention); this cannot be planned around
- Housing is the real cost: you must hold a Monaco lease or deed, and rents and prices are among the highest in the world
- Banks expect a large deposit for the reference letter; the amount is set by each bank, not the state
Portugal
SituationalThe old NHR regime has closed; its replacement (IFICI) suits only certain professions.
Approx. flight time from London: about 2½ h to Lisbon
How the client would be taxed there
- Tax system
- Worldwide, with IFICI exemption for qualifying newcomersSecondaryKPMG GMS Flash Alert 2025-044 - Portugal IFICI · checked 2026-09-29
- Dividends
- 28%SecondaryPwC Worldwide Tax Summaries - Portugal, Individual, Income determination · checked 2026-09-29
- Capital gains
- 28%SecondaryPwC Worldwide Tax Summaries - Portugal, Individual, Income determination · checked 2026-09-29
- Income tax, top rate
- 48% (+2.5%/5% solidarity surcharge)SecondaryPwC Worldwide Tax Summaries - Portugal, Individual, Taxes on personal income · checked 2026-09-29
- Inheritance
- 0% for childrenUnverifiedPwC Worldwide Tax Summaries - Portugal, Individual, Taxes on personal income · checked 2026-09-29
- Wealth tax
- NoneUnverifiedPwC Worldwide Tax Summaries - Portugal, Individual, Taxes on personal income · checked 2026-09-29
- Becoming tax resident
- 183 days, or a habitual homeUnverifiedPwC Worldwide Tax Summaries - Portugal, Individual, Income determination · checked 2026-09-29
- UK tax treaty
- Yes - new 2025 conventionVerifiedGOV.UK - Portugal: tax treaties · checked 2026-09-29
The residence route
EU residence with little time on the ground, through the fund golden visa.
EUR 500,000 (~USD 575,000) in qualifying Portuguese investment funds. The funds must hold at least 60% in Portuguese companies and have at least 5 years to maturity. Property purchase and pure capital transfer were removed as routes in 2023. Other routes remain: EUR 500,000 into research, EUR 250,000 into arts and heritage, company capital plus job creation. The stay requirement averages about 7 days a year.
Investment from USD 575,000 · Minimum stay: 7 days a year
AIMA - Agency for Integration, Migration and Asylum (residence permits) · checked 2026-09-29Regimes to know about
- IFICI ("NHR 2.0") - Tax Incentive for Scientific Research and InnovationSecondary
20% flat rate on qualifying Portuguese employment or self-employment income, and exemption with progression for most foreign-source income (salary, business, dividends, interest, rent, gains). Blacklisted-jurisdiction income is taxed at 35%, and foreign pensions are not covered.
KPMG GMS Flash Alert 2025-044 - Portugal IFICI · checked 2026-09-29 - Non-Habitual Resident (NHR) - closedSecondary
The original NHR regime was closed to new applicants from 2024. It survives only for people already registered and for limited transitional cases. Do not plan a move around it.
KPMG GMS Flash Alert 2025-044 - Portugal IFICI · checked 2026-09-29
Watch-outs for this client
- IFICI is not for passive investors or retirees: you need a qualifying job or activity, and you must register by 15 January of the year after you arrive
- Foreign pensions get no IFICI relief, and anything from a blacklisted jurisdiction is taxed at 35%
- Golden visa can no longer be done through property; fund quality and lock-up matter
For comparison: staying in the UK
- Dividends
- 10.75% / 35.75% / 39.35%VerifiedGOV.UK - Income Tax rates and allowances: current and past · checked 2026-09-29
- Capital gains
- 18% / 24%VerifiedGOV.UK - Budget 2025 overview of tax legislation and rates, Annex A: rates and allowances · checked 2026-09-29
- Inheritance
- 40% above £325,000VerifiedGOV.UK - Reforming the taxation of non-UK domiciled individuals · checked 2026-09-29
Section 4
What the UK still claims
The client's answers, read against the UK rules for leavers in a fixed order. Result: 48/100, Gaps to close. Every rule that applies:
- 1Inheritance tax follows you for 10 years after you leavehigh
20 UK-resident years out of 20 makes you a long-term resident: your worldwide estate stays within UK inheritance tax for 10 years after you leave, which matters for gifts to your family and life cover.
Inheritance tax: long-term residence tailVerified
HMRC Inheritance Tax Manual IHTM47020 - Long-term UK residence test · checked 2026-09-29 - 2UK rent: tax is withheld unless HMRC approves gross paymentmedium
Once you live abroad, your agent or tenant must deduct basic-rate tax from UK rent unless HMRC has approved you under the Non-Resident Landlord scheme. Apply before you go.
Non-Resident Landlord schemeVerified
GOV.UK - Paying tax on rent to landlords abroad (Non-Resident Landlord scheme) · checked 2026-09-29 - 3Moving your pension abroad can cost a quarter of itmedium
A transfer to an overseas scheme (QROPS) can trigger the overseas transfer charge unless you live in the same country as the scheme, and it can still bite if you move within five full tax years.
Overseas transfer charge on pension transfers (QROPS)Verified
HMRC - The overseas transfer charge guidance · checked 2026-09-29 - 4A sale while you are away is taxed if you come back within five yearslow
You do not plan to return, but if plans change, a company sale or large gain made while away on shares you held before leaving is taxed in the year you come back.
Temporary non-residence: the five-year ruleVerified
HMRC HS278 Temporary non-residents and Capital Gains Tax (2026) · checked 2026-09-29 - 5Your UK company does not move with youlow
A UK-incorporated company stays UK resident. Run it from your new country and that country may say it is resident or has a permanent establishment there too. Decide where the board really decides, and make the facts match.
Company residence: UK incorporation and central management and controlVerified
Corporation Tax Act 2009, section 14 · checked 2026-09-29 - 6Selling UK property: report within 60 dayslow
Non-residents must report every UK property sale, and pay any tax, within 60 days of completion, even when no tax is due.
Non-resident CGT on UK property: 60-day reportingVerified
GOV.UK - Capital Gains Tax for non-residents: UK residential property · checked 2026-09-29 - 7Tell HMRC you are leavinglow
Use form P85, or the residence pages (SA109) of your Self Assessment return. HMRC's online services cannot be used to report departure.
Telling HMRC you have left: P85 or SA109Verified
GOV.UK - Tax if you leave the UK to live abroad · checked 2026-09-29
Already in the client's favour
- Sufficient ties test: 1 UK tie against 4 needed at 40 days.
- Day limit
- Under 16 UK days = non-resident (if resident in 1+ of the last 3 years)VerifiedHMRC - RDR3 Guidance note for Statutory Residence Test · checked 2026-09-29
- Split-year Case 3
- Case 3: fewer than 16 UK days after your UK home endsVerifiedHMRC Residence and FIG Regime Manual RFIG21130 - Split year Case 3 · checked 2026-09-29
- Five-year rule
- Away 5 years or less = gains taxed on returnVerifiedHMRC HS278 Temporary non-residents and Capital Gains Tax (2026) · checked 2026-09-29
- Inheritance tax tail
- IHT tail: 3 years (13 or fewer years resident) up to 10 years (20+ years resident)VerifiedHMRC Inheritance Tax Manual IHTM47020 - Long-term UK residence test · checked 2026-09-29
- When the tail ends
- Scope ends after 10 consecutive years of non-residenceVerifiedHMRC Inheritance Tax Manual IHTM47020 - Long-term UK residence test · checked 2026-09-29
Section 5
The company when you leave
The founder moving does not move the company. It stays UK resident and keeps paying UK corporation tax; the risk runs the other way, if the new country decides the company is now managed there. For a sale planned within three years, the order matters: leave cleanly first, run the board from where the company is meant to be resident, and model the five-year rule before signing.
- Company residence
- Moving abroad does not move your UK companyVerifiedCorporation Tax Act 2009, section 14 · checked 2026-09-29
- Where the board decides
- Where the board really decides = where a foreign company is residentUnverifiedHMRC International Manual INTM120000 - Company residence · checked 2026-09-29
- Dividends while away
- Dividends from your own company while away are taxed when you come backVerifiedHMRC Residence and FIG Regime Manual RFIG21600 - Temporary non-residence: distributions from closely controlled companies · checked 2026-09-29
From the Latitax UAE file: A UK-managed UAE company can be UK tax resident under central management and control, and UK CFC rules may apply if UK residents control it.
Section 6
Dated exit checklist
Dates are illustrative for this fictional client, who leaves early in the 2027/28 tax year. The steps are the Latitax guide's, in order.
October 2026 to March 2027
Before you leave
- Before you set a date: model the tax year. Pick the departure date so that you fit a split-year case, check how long your IHT tail will be, and decide whether any sale or large dividend could fall inside a five-year TNR window.
- Settle the company question. Decide where your company should be resident, rearrange the board if needed, and take advice in the new country on permanent establishment and payroll.
- Cut ties deliberately. Sell, let on a long lease, or otherwise make the UK home unavailable if you need Case 3 or want to keep ties low; count family, accommodation, work and 90-day ties for the next two years, not just this one.
April 2027
The tax year you leave (2027/28)
- Tell HMRC. If you do not normally file Self Assessment, use form P85. If you do, report departure on the residence pages (SA109) of your return. People working full-time abroad for a UK employer need P85 as well.
- Tell your banks and brokers. Under the Common Reporting Standard, financial institutions ask where you are tax resident and report your accounts to that country. Update your self-certification promptly; a stale UK address keeps you on UK reports and a false one is an offence.
- Deal with UK property: apply to receive rent gross under the NRL scheme, and diarise the 60-day reporting rule for any future sale.
2027/28 onwards
The first five years abroad
- Protect your state pension. From 6 April 2026 voluntary Class 2 contributions for periods abroad have gone; only Class 3 is available, and new applicants need 10 continuous years of UK residence or 10 qualifying years on their record. The Class 3 rate for 2026-27 is £18.40 a week. Existing Class 2 payers have until 5 April 2027 to switch under the old three-year test.
- Keep evidence, every year. A day log with travel records, where you slept, where you worked more than three hours, and proof of your new home and residence (a tax residence certificate from the new country). If HMRC asks, the burden is on you.
Section 7
Questions for your advisers
- Given our planned departure date, which split-year case do we fit, and what exactly must happen to the London home and the let flat for it to apply?
- How many UK ties will we have in each of the next three tax years, and how many UK days does that leave us?
- If the company sale completes while we are abroad, what happens if we return within five years, and should the sale wait?
- Should the company pay any dividend before we leave, or none until after the five-year window?
- Where will the board meet and decide after we move, so the company stays resident where we intend and does not create a permanent establishment abroad?
- How do we plan gifts, trusts and life cover around the inheritance tax tail, and when does it end for each of us?
- Should the let flat be approved to receive rent gross under the Non-Resident Landlord scheme, and who files our UK returns?
- Should the pension stay in the UK, and how would withdrawals be taxed under the treaty with our new country?
- In the UAE: which residence and tax residency certificate route suits us, and what evidence of days and home will banks and HMRC want?
- In the new country: is there anything we must register for, or apply for, before or on arrival?
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See membershipSample report for a fictional client. Latitax research, not legal or tax advice. Figures are from the Latitax database with the sources and dates shown; secondary and unverified figures are marked. Rules change: confirm every step with a qualified adviser in each country before acting. Run the free Exit Readiness check on your own situation.