Reference
Glossary
The tax, residency, structuring and governance terms that recur in cross-border wealth planning — defined plainly, with the distinction that actually matters in each case.
Tax Relocation
Exit Tax
An exit tax is a charge triggered by ceasing tax residence, typically levied on unrealised gains as though assets had been sold on the date of departure. It is a timing mechanism: it accelerates a liability that would otherwise arise on a future disposal, rather than creating a new class of tax.
Deemed Disposition
A deemed disposition treats an asset as sold at market value on a specified date even though no sale occurred, crystallising any gain for tax purposes. It is the mechanism most emigration charges use: residence ceases, assets are deemed sold that day, and the resulting gain becomes taxable.
Statutory Residence Test
The Statutory Residence Test (SRT) is the UK's codified test for determining whether an individual is UK tax resident in a given tax year. Introduced with effect from the 2013/14 tax year, it comprises automatic overseas tests, automatic UK tests, and a sufficient ties test applied in that order.
Non-Dom
Non-dom described a UK resident whose permanent home (domicile) was treated as outside the UK, historically allowing foreign income and gains to be taxed only when remitted to the UK. The UK removed domicile as a connecting factor for income tax, capital gains tax and inheritance tax from 6 April 2025, replacing it with a residence-based regime.
Temporary Repatriation Facility
The Temporary Repatriation Facility (TRF) is a time-limited UK regime allowing former remittance-basis users to designate pre-6 April 2025 foreign income and gains and bring them into the UK at a reduced flat rate. It runs for three tax years from 6 April 2025.
Tax Residency Certificate
A Tax Residency Certificate (TRC) is an official document confirming that a person or entity was tax resident in a jurisdiction for a given period. In the UAE it is issued by the Federal Tax Authority and is the standard evidence required to claim relief under a double taxation agreement.
Jurisdictions
DIFC
The Dubai International Financial Centre (DIFC) is a financial free zone established in Dubai in 2004. It operates its own civil and commercial legal framework based on common law, with independent DIFC Courts and a dedicated regulator, the Dubai Financial Services Authority (DFSA).
ADGM
Abu Dhabi Global Market (ADGM) is a financial free zone on Al Maryah Island, Abu Dhabi, established in 2013 and operational from 2015. It applies English common law directly, including English statutes as they apply from time to time, and is regulated by the Financial Services Regulatory Authority (FSRA).
Disclaimer. These definitions are provided for general reference and do not constitute tax, legal, or financial advice. Rules and thresholds change, and individual circumstances vary significantly. Consult a qualified adviser before acting on any of them.
