In September 2026, news emerged that hedge fund billionaire Chris Rokos was contemplating a move from London to Athens, adding his name to a growing roster of high-net-worth individuals seeking opportunities beyond the United Kingdom. Rokos, notably ranked by the Sunday Times as the UK’s third-highest taxpayer with a reported £330 million paid in the previous year, represented a significant potential loss for the UK’s exchequer. Weeks later, property magnate David Reuben was reportedly relocating to Monaco. These high-profile departures underscore a broader trend, placing immense pressure on tax lawyers to manage the intricate legal and financial ramifications of international relocation for their ultra-wealthy clients.
The implications for legal professionals, particularly those featured in Spear’s 2026 Tax Lawyers Index, extend far beyond facilitating a change of address. Advising clients who are severing their UK tax residence involves navigating a complex web of international tax treaties, domicile rules, and residual liabilities that can linger for years. Simultaneously, tax lawyers remaining in Britain are increasingly engaged in advising families on restructuring businesses and property holdings to ensure smoother intergenerational wealth transfer amidst evolving tax legislation. With the UK’s tax landscape subject to ongoing review, exemplified by the recent Budget delivered under Chancellor Jeremy Burnham, the demand for expert legal counsel in this domain shows no signs of diminishing.
Themes Shaping the 2026 Tax Landscape
Beating the Clock: The Inheritance Tax Imperative
For many affluent families considering their future in Britain, inheritance tax has superseded income tax as the primary concern. Helen Clarke of Irwin Mitchell highlights that her international clientele, while generally accepting of the UK’s tax regime on income and investments, express greater apprehension regarding their worldwide assets potentially falling under the UK’s inheritance tax jurisdiction. For individuals who never intended to make Britain their permanent home, this prospect is a significant deterrent, prompting proactive decisions to leave before accruing such liabilities.
Liz Palmer of Howard Kennedy observes that the government may have underestimated the wealthy’s propensity to act on significant tax changes. "The perception that they could make significant changes and only a modest number of people would change their behaviour or only a modest number would leave the UK, that was really quite a significant misconception," she states. This sentiment is echoed by Wilfrid Vernor-Miles of Hunters Law, who notes that many of his clients already possess residences in multiple countries. Rather than complete upheaval, these individuals are strategically reducing their time spent in Britain to manage their UK tax residence. Others are proactively securing the right to reside in a second country without immediate plans to relocate, maintaining flexibility should their circumstances or the UK’s tax environment change.
The New Map of Wealth: Evolving Destinations
The choice of destination for relocating ultra-high-net-worth individuals (UHNWs) is also undergoing a transformation. Dubai, once a favoured hub, experienced a decline in its reputation for safety following drone strikes in March 2026, impacting its appeal as a secure base for international business and personal affairs. Clarke notes that while she had been advising clients on relocating to the UAE, the conflict has led some to explore Portugal or Italy as alternative bases while reassessing their long-term settlement plans.
Italy has emerged as a significant beneficiary, even with an increase in its annual flat tax for wealthy new residents to €300,000. Alberto Brazzalotto of Maisto e Associati reports that his firm has handled over a third of all requests to the Italian tax authority for formal confirmation on the taxation of prospective residents’ trusts and companies. At Charles Russell Speechlys, Nicola Saccardo has overseen the expansion of the firm’s Italian practice from two lawyers to over twenty in just four years, driven by Milan’s increasing appeal to wealthy international residents.
The Americans: A Cautious Influx
In contrast to the outward flow, the UK continues to see an influx of American citizens. Alexis Hille of Farrer & Co observes US clients seeking a foothold in the UK, even if they do not intend to become fully tax resident. This often manifests as acquiring London property or securing places at British schools for their children, acting as a "safety net."
This demographic shift is reshaping legal practices. Matthew Radcliffe of Russell-Cook points out that his work has transitioned from being primarily that of a non-dom private client lawyer to serving clients with a US or Canadian nexus, encompassing both Britons moving to America and Americans moving to the UK. Ben Rosen of Quastels has strategically repositioned his practice towards US-connected clients, and Joshua Ryan at Weightmans reports that approximately 40% of his work is US-related. Emma Gillies of Forsters indicates that this figure reaches as high as 90% for her practice.
Many American clients arrive with limited understanding of the UK’s more stringent tax regulations compared to their home country, particularly concerning estate tax exemptions and the routine use of trusts for lifetime planning. Gillies notes that the loss of excluded property trust planning under new UK rules has been a significant and unwelcome surprise for clients arriving with pre-existing trust structures. Hille adds, "It’s so common to use them in the States for lifetime planning. And here it can be really tricky. So a lot of the advice is what not to do, or the advice is looking at what they’ve already done and trying to make it not so bad."
The Taxman’s Evolving Arsenal
While legal professionals navigate these complex client needs, Her Majesty’s Revenue and Customs (HMRC) is enhancing its investigative capabilities. The authority reported that digital analytics and Artificial Intelligence (AI) contributed to approximately £10 billion in tax collected or protected in the 2025-26 fiscal year, a period that saw HMRC’s compliance yield reach a record £50.2 billion. According to Pinsent Masons, HMRC now achieves a return of £35 for every pound invested in investigations. This increased efficiency has also led HMRC to directly contact billionaires with a UK tax footprint, seeking details about their financial affairs.
Chris Moorcroft of Harbottle & Lewis observes a shift in his practice, with less emphasis on inbound tax advisory and a greater volume of tax enquiry and investigation work. Adam Craggs of RPC describes AI as a potential "game changer" for HMRC, enabling the analysis of vast datasets previously unmanageable. He has represented cryptocurrency entrepreneurs whose tax enquiries were triggered by data from trading platforms, noting that investigations can typically span three to eight years.
The stakes in these disputes are substantial. David Pickstone, founder of Stewarts’ tax disputes practice, successfully settled one aspect of a dispute for former owners of a consumer business who had relocated abroad, averting a potential £50 million liability HMRC had initially sought. At Druces, Robert Macro’s team meticulously compiles source-of-wealth records for families whose historical industry or jurisdictional links attract scrutiny from banks, often reconstructing decades of financial history, with one case file extending to 55 boxes of documentation. Simon Malkiel of Howard Kennedy offers a pragmatic approach: "If they ask the question about how HMRC find out, the advice is: assume they will find out, plan on that basis. Your digital footprint is more than a footprint. It’s a proper imprint."
Methodology: Spear’s Research Approach
The Spear’s Research Unit employs a rigorous methodology to compile its annual rankings of leading legal and financial advisors. This process involves gathering comprehensive data on advisors and firms through submission forms, nominations, peer reviews, third-party data analysis, and extensive interviews. A proprietary scoring system, with varying weightings for different attributes, is applied to assess each advisor, feeding directly into the Spear’s Indices. These indices are initially published online, adhering to the research calendar, and subsequently featured in print within the annual Spear’s 500 directory, which showcases the top advisors across all indexed sectors. Profiles of featured advisors are available on spears500.com, allowing users to search for professionals based on location, expertise, and client base.
The Best Tax Lawyers: A Closer Look
Filippo Noseda
Filippo Noseda of Mishcon de Reya offers a comprehensive suite of private client services, including international tax law, family governance and succession planning, trust structuring, and philanthropic foundations. He also handles immigration planning for affluent families, particularly those relocating to or from the UK due to non-domicile rule changes. Noseda, a dual-qualified English and Swiss lawyer, possesses fluency in English, Italian, German, and French, enabling seamless management of cross-border matters for his internationally oriented clientele.
Robert Brodrick
Robert Brodrick, a partner and former chair of the management board at Payne Hicks Beach, provides high-level private client advice that extends beyond tax obligations. He notes a significant evolution in his role over two decades, moving from a tax-centric focus to a blend of tax, succession, and family governance advice. His practice increasingly involves cross-border work, with a particular emphasis on the Middle East, frequently requiring him to meet with families to discuss the establishment and restructuring of their trusts and UK property holding structures, as well as advising offshore trustees.
Alexandra Hollingshead
Alexandra Hollingshead, a partner at Farrer & Co, advises trustees, UHNW beneficiaries, settlors, and family business owners on intricate trust structures holding substantial dynastic wealth. Since 2023, she has also led the firm’s pro bono and community initiatives, including a project providing end-of-life legal advice to young adults with terminal cancer. Hollingshead, recognized as Spear’s Tax Lawyer of the Year in 2025, emphasizes maintaining the same high standard of commitment and dedication across both her pro bono and fee-paying work.
Nick Warr
Nick Warr of Winston Taylor specializes in financial and succession planning for a significant cohort of finance executives, hedge fund managers, and private equity principals from leading organizations. His work, often valued in the £500 million-plus range, typically involves multiple jurisdictions. A notable case involved advising a globally prominent family worth over £6 billion on their personal and business affairs, where Warr and his team served as lead advisors.
Beatrice Puoti
Beatrice Puoti, partner and head of private wealth at Stephenson Harwood’s London office, manages a truly global practice, advising individuals, family offices, and international families on complex cross-border tax, trust, and estate planning. She is also involved in trustee decision-making, family disputes, and trust restructurings. Puoti’s expertise with European clients is notable, owing to her fluency in English, Italian, French, and Spanish, coupled with Roman and common law qualifications, allowing her to construct robust and tax-efficient solutions applicable across jurisdictions.
Russell Cohen
Russell Cohen heads international strategy at Farrer & Co, assisting HNW individuals, their families, trustees, and family offices with wealth structuring. His guidance encompasses wealth preservation, succession planning, tax planning, and family governance, with a significant international component. Cohen is a founding member of STEP’s responsible stewardship of wealth thought leadership group and serves on the editorial board for the International Family Offices Journal, specializing in tax planning for globally mobile individuals and non-UK trusts.
John Annetts
As head of private wealth at Howard Kennedy, John Annetts oversees a department covering private client and family law, trust and estate disputes, high-value real estate, and art law. A chartered tax advisor, he manages complex estate administration and succession planning for entrepreneurs and senior executives. His cross-border estate administration work includes a multi-jurisdictional, billion-pound estate involving the tracing of concealed assets. His planning work is equally substantial, having advised executives whose fortunes were projected to exceed £250 million following a company transaction.
Laura Dadswell
Laura Dadswell is a distinguished international tax and trust specialist at Penningtons Manches Cooper, with particular expertise in US-related matters and corporate wealth structuring. Described as a standout private client lawyer of her generation, she provides bespoke and sensitive solutions for wealth management. Dadswell emphasizes an empathetic approach, striving to understand client perspectives to deliver tailored and digestible advice.
David Pickstone
David Pickstone established Stewarts’ tax disputes department in 2014 and has since handled numerous high-profile cases. His focus is on developing strategic plans to achieve the best outcomes for clients, prioritizing discretion and confidentiality. His clients, including UHNW individuals, family offices, and businesses, often seek his expertise to avoid litigation. Pickstone highlights his team’s ability to provide strategic insight for resolving disputes without resorting to court proceedings, aligning advice with clients’ broader objectives.
The landscape of international wealth management and taxation is in constant flux, demanding adaptability and deep expertise from tax lawyers. As global economic and political conditions shift, so too do the strategies employed by wealthy individuals and the tools utilized by tax authorities, ensuring that the field of tax law remains a dynamic and critical area of legal practice.
