• Sectors we work in banner(2)

    Quick Reads

Business as usual for Family Investment Companies

min read

In April 2019, HM Revenue & Customs (HMRC) set alarm bells ringing when they established a specialist unit to examine the use of Family Investment Companies (FICs).  The aim of this review was to examine, amongst other things, the common characteristics of FICs, the age and wealth profile of the people establishing them and whether there was a correlation between those who operate FICs and non-compliant behaviours.

The team has now completed its review and presented its results to the Wealthy External Stakeholders Forum.  In summary, HMRC have concluded that the use of FICs appears to be a planning strategy, often with the primary objective of generational wealth transfer and the mitigation of Inheritance Tax, and that there is no evidence to suggest that there is a correlation between those who establish a FIC structure and non-compliant behaviours.  HMRC have further noted that there is some diversity in the way that FICs are structured and managed, creating tax risks and compliance activity across a variety of tax regimes, including Inheritance Tax, Capital Gains Tax, Stamp Duty Land Tax and Corporation Tax.

HMRC have therefore closed the dedicated FIC team and confirmed that FICs will now be looked at by HMRC as ‘business as usual’.

However, HMRC would not confirm whether they are seeking to introduce specific FIC legislation and so we cannot rule out the introduction of targeted legislation or anti-avoidance measures in the future.

The use of FICs appears to be a planning strategy, often with the primary objective of generational wealth transfer and mitigation of Inheritance Tax.

Our thinking

  • Sarah Jane Boon comments in the Law Society Gazette on the legal realities behind Sky’s divorce drama War

    Sarah Jane Boon

    In the Press

    min read
  • The Bayeux Tapestry: threading the needle on art loans

    Suzanne Marriott

    Insights

    min read
  • The Swiss Lump Sum Tax Series: Part 2 - Pre-Relocation Wealth Structuring

    Frédéric Ney

    Insights

    min read
  • Harriet Betteridge comments in Professional Adviser on the six-month countdown to UK pension inheritance tax changes

    Harriet Betteridge

    In the Press

    min read
  • Charles Russell Speechlys wins Private Client Law Firm – Ultra-High Net Worth 2026 at eprivateclient Excellence Awards

    Piers Master

    News

    min read
  • Lost and found: how to trace forgotten Swiss pension assets, and why it matters on divorce

    Joanna Metaxas

    Insights

    min read
  • IBA Annual Conference 2026

    Jean-Baptiste Beauvoir-Planson

    Events

  • Swiss Pension Assets After Moving Abroad: What You Need to Know

    Aline Wey Speirs

    Insights

    min read
  • My child is engaged – how do I raise the issue of a prenuptial agreement?

    Julia Cox

    Insights

    min read
  • Vadim Romanoff and Shaanil Senarath-Dassanayake consider the risks and rewards of digital assets for family offices in eprivateclient

    Vadim Romanoff

    In the Press

    min read
  • 10 ways the new APR/BPR rules affect estate administration

    Mary Perham

    Insights

    min read
  • Wait For It: Cohabitation Reform, Schedule 1 and the Unmarried Family

    Cara Fung

    Quick Reads

    min read
  • Gifts to Children: Balancing Protection, Incentive and Control

    Sally Ashford

    Insights

    min read
  • The Swiss Lump Sum Tax Series: Part 1 - The Swiss Lump Sum Tax Regime, Explained Differently

    Frédéric Ney

    Insights

    min read
  • Julia Cox, Mary Perham and Bronwen Bernstein write in Wealth Briefing about potential CGT changes in the UK Autumn Budget

    Julia Cox

    In the Press

    min read
  • Do I have to try mediation before making a family court application?

    Sarah Anticoni

    Insights

    min read
  • Unfair dismissal: What Private Client employers need to know before 1 January 2027

    Chiara Muston

    Insights

    min read
  • Bloomberg quotes Dominic Lawrance on the wealth hubs available to globally mobile high-net-worth individuals

    Dominic Lawrance

    In the Press

    min read
  • Landed Estates – UK Wide: Overview

    Sarah Wray

    Insights

    min read
  • Arbitration of Trust Disputes Webinar

    Thomas R. Snider

    Events

    min read
Back to top