TAX PLANNING — 2026
Family Office Tax Planning in 2026 — UK Private Wealth Magazine
The 2026 tax planning environment for UK and internationally active family offices is the most complex and consequential in a generation — combining IHT reform, the FIG regime, the TRF window, carried interest tax changes and the global minimum tax under Pillar Two. UK Private Wealth Magazine covers family office tax planning as a core editorial topic across every issue.
The Seven Tax Issues Family Offices Cannot Ignore in 2026
1. The TRF window closes 5 April 2028
Pre-April 2025 offshore income and gains must be remitted at 12% or 15% by that date or the opportunity is lost permanently. For families with large offshore balances, this is the most time-sensitive planning decision of the year.
2. Residence-based IHT requires immediate structure review
Families approaching 10 years of UK residency face a material change in their worldwide IHT exposure. Offshore structures may need to be reviewed before the 10-year mark.
3. FIG regime must be planned from day one
The four-year relief window for new UK residents is most valuable when planned carefully from the outset — not claimed retrospectively.
4. Carried interest tax treatment changed
The new carried interest tax regime — moving from CGT to income tax treatment for most qualifying carried interest — is directly relevant to family offices with private equity and venture capital fund positions.
5. UK corporate tax at 25% is now among the higher European rates
Family offices with UK corporate holding structures should assess whether restructuring through a lower-tax jurisdiction offers genuine long-term benefit after transition costs.
6. The OECD Pillar Two global minimum tax applies to large family office groups
The 15% global minimum tax applies to groups with annual revenue above €750 million — relevant for large family businesses that have converted to family office holding structures.
7. Digital asset tax treatment continues to evolve
HMRC's treatment of cryptocurrency and digital assets as chargeable assets for CGT purposes means family offices with digital asset exposure require specific planning.
Practitioner Contributions for Issue Two
UK Private Wealth Magazine welcomes editorial contributions from tax advisers and lawyers on all seven topics above. Issue Two: Capital Under Pressure publishes July 2026. Deadline: Monday 13 July 2026.
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Frequently Asked Questions
What are the most urgent tax planning issues for family offices in 2026?
The TRF window closure, residence-based IHT, FIG regime planning, the new carried interest treatment, UK corporate tax positioning, OECD Pillar Two, and the evolving treatment of digital assets.
When does the TRF window close?
5 April 2028. Pre-April 2025 offshore income and gains must be remitted at 12% (2025-26) or 15% (2026-27 and 2027-28) before that date.
Does Pillar Two affect family offices?
The 15% global minimum tax applies to groups with annual revenue above €750 million — relevant for large family businesses that have converted to family office holding structures.
How do I contribute editorial?
Tax advisers and lawyers may submit educational, non-promotional contributions for Issue Two. Submit here. Deadline: Monday 13 July 2026.