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Executive Matters

Issue 10: May 2025

Executive Matters

Editor's note

Daniel Naftalin - Mishcon de Reya

Welcome to the latest edition of Executive Matters, our quarterly publication tailored to the challenges and legal issues faced by Senior Executives. 

As many of you will know, the Finance Act 2025 has resulted in seismic shifts to the "non-dom" tax regime. We have therefore produced a handful of short videos explaining the main changes, including the new rules around foreign income and gains; the various reliefs available; and specific considerations for US-UK connected persons.   

Turning to the Boardroom, we discuss the judgment from Rukhadze & Ors v Recovery Partners, in which the Supreme Court gave a sobering reminder that there is no escape from accounting for personal profits arising from a fiduciary relationship – even if you don't know that you are a fiduciary! We also look at Companies House's new verification processes for directors, PSCs and persons filing documents on behalf of companies.    

For more information on the key issues facing the Boardroom, you can access our For the Attention of the Board briefing series. This provides concise, actionable insights on such issues as EDI, sanctions regimes, Health & Safety compliance, and ESG reporting – all from the perspective of the Board. We also offer briefings on ESG-related matters specifically, as part of our ESG for Business Leaders series. Details of both are below.  

Finally, we conclude with the inspirational story of Ed Currie and Andy Coxon – two former West End dancers whose gruelling (and sweaty) schedule led them to found their own deodorant brand, the award-winning AKT London. You can listen to their exploits - including the perils of creating deodorant in the kitchen - as part of our Jazz Shapers podcast

Video
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A new era for non-doms

The new tax year began on 6 April, ushering in a new era for non-doms. Partner and Head of Private Wealth and Tax Charlie Sosna and Managing Associate Annie Bouch sat down to discuss the new regime, including the effect of the Finance Act 2025 and "FIG relief".

Video
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A new era for non-doms: UK/US landscape

Patrick Harney and Hannah Dart discuss the UK's new tax regime's impact on US citizens, who face worldwide taxation. Despite concerns, interest remains high. They highlight strategies to prevent double taxation and mitigate UK inheritance tax through treaties, and advise seeking UK tax advice to navigate potential liabilities under the "FIG regime.

Video
business people

A new era for non-doms: What is the TRF?

The new tax year began on 6 April, ushering in a new era for non-doms. Private Wealth Managing Associate Annie Bouch and Of Counsel Hannah Dart discuss the UK's new tax regime for non-domiciled residents, focusing on the temporary repatriation facility (TRF).

Video
commercial buildings

A new era for non-doms: How will a rebasing election work?

The new tax year began on 6 April, ushering in a new era for non-doms. Private Wealth and Tax Partner Andrew Goldstone and Managing Associate Nicola Simmons discuss the UK's new FIG regime, which allows tax-free use of foreign income or gains for four years.

Video
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A new era for non-doms: What does it mean for Trustees?

The new tax year began on 6 April, ushering in a new era for non-doms. Private Wealth and Tax Managing Associate Moustapha Hammoud and Legal Director Katie Doyle discuss how the new rules affect trusts established by non-domiciled settlors.

News
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Fiduciaries beware as Supreme Court confirms there's no escape from accounting for profits

Richard Leedham and Frances Beddow discuss Rukhadze & Ors v Recovery Partners GP Ltd & Anr [2025] UKSC 10 where the UK Supreme Court reaffirmed the strict accountability of fiduciaries, rejecting a "but for" causation test for profits made from fiduciary relationships. The ruling emphasises that fiduciaries must account for all profits unless informed consent is obtained, underscoring the importance of understanding fiduciary obligations.

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Companies House reform next steps: ID verification coming soon

As part of its commitment to deter the use of corporate entities for illegal purposes, Companies House is introducing new identity verification requirements for directors, people with significant control (PSCs) and persons filing documents on behalf of companies. Individuals will soon be able to verify their identities voluntarily – doing so early will allow them to get ahead of mandatory verification and avoid situations down the line where, for example, a director is unable to act or a Companies House filing cannot be made. Once identity verification is mandatory, it will be an offence for a director to act without having had their identity verified.

News
Woman speaking in front of Mic

ESG for business leaders

Today, more is expected of businesses than ever before. It is crucial for all business leaders to understand the full ESG landscape in order to be equipped to identify and address material risks, opportunities, dependencies and impacts across their businesses and value chains.

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