Family office in London: FCA perimeter, UK structures and the post-2025 tax regime

London is one of the most established family office centres in the world. Families use it for proximity to asset managers, private banks, private equity and venture capital, English law and courts, and an advisory market experienced in cross-border succession. The flip side is that the UK taxes its residents on worldwide income and gains and applies inheritance tax to long-term residents' worldwide estates, so a London office is a structuring decision that should be taken together with residence planning. Families with assets held in the Channel Islands often run investment oversight from London while trusts and PTCs sit in Jersey or Guernsey.

There is no single family office exemption in UK financial services law. Section 19 of the Financial Services and Markets Act 2000 prohibits carrying on a regulated activity by way of business without authorisation or exemption. A family office managing investments, advising or arranging deals for family members must therefore work through the perimeter: whether its activities are regulated at all, whether they are carried on by way of business under the Carrying on Regulated Activities by Way of Business Order 2001, and whether exclusions apply, most commonly the Article 69 group exclusion in the Regulated Activities Order where the office acts for companies in the same group. Risk areas include charging non-family clients, inviting paid co-investors, raising capital for investee companies or lending to relatives. An AIFMD analysis is also needed: FCA perimeter guidance (PERG 16) reflects the position that family investment vehicles investing the private wealth of a family without raising external capital are not alternative investment funds. Offices serving several unrelated families normally need Part 4A permission or act as an appointed representative of an authorised regulatory host.

The tax backdrop changed fundamentally on 6 April 2025. The remittance basis for non-domiciled individuals was abolished. Individuals who become UK resident after ten consecutive years of non-residence can claim 100% relief on foreign income and gains for their first four years of residence (the FIG regime); Overseas Workday Relief runs for the same four years, capped at the lower of £300,000 or 30% of employment income. Former remittance basis users may designate pre-April 2025 foreign income and gains under the Temporary Repatriation Facility at 12% for 2025-26 and 2026-27 and 15% for 2027-28, and can rebase foreign assets held on 5 April 2017. Inheritance tax now depends on long-term residence: anyone UK resident for at least 10 of the previous 20 tax years is within scope on worldwide assets, with a tail of three to ten years after leaving. Non-UK assets settled into trust are within relevant property charges while the settlor is long-term resident, with transitional rules and a cap for certain pre-30 October 2024 excluded property trusts.

From 6 April 2026, 100% business property relief and agricultural property relief are limited to a combined £1 million per individual, with 50% relief above that; AIM and other 'not listed' shares receive 50% relief in all cases. Budget 2025 made the unused allowance transferable between spouses and civil partners and froze it, together with the £325,000 nil-rate band, until 5 April 2031. From 6 April 2027 unused pension funds will fall into the estate. Dividend tax rates rose by 2 points from 6 April 2026 (ordinary 10.75%, upper 35.75%), and savings and property income rates rise in April 2027. These changes make the family investment company and the choice of trust jurisdiction central to London-based planning.