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I focus on UK and international tax, trusts and immigration.
My areas of expertise include advising high-net worth individuals and families and their companies and trustees on complex and cross-border tax-planning, estate-planning and trust structuring. This includes assisting them to structure personal investments and interests tax-efficiently and planning for their successful transmission to the next generation.
I act in particular for non-UK nationals and non-UK domiciliaries and those who wish to relocate to or exit from the UK.
“Alex Ruffel ‘is excellent technically on complex cross-border work'” - Legal 500 2015
“Alexandra Ruffel is praised by peers for her technical ability. She concentrates on sophisticated trust and tax issues, and is also able to advise on immigration matters” - Chambers & Partners 2016
“We are very glad to finally have some clarity after three months of uncertainty as to whether, when and in what form the changes to the taxation of long-term UK resident non-doms and taxation of UK residential property would be reintroduced. “The backdating of the effect of the new legislation to 6th April 2017 will be welcomed by non-doms who took steps to utilise rebasing relief and plan for the mixed fund rules in reliance upon the original Finance Bill. However, there may be others who acted in reliance upon the current law who will face tax liabilities as a result. “There are also some interesting practical questions. For example, if a trust appointed shares in a non-UK company owning UK residential property on 7 April 2017 will they have any leeway on time limits for submission of an inheritance tax account, given that it was not clear whether one was needed until over three months later? “The announcement from the Treasury acts as a great starting point, but should be treated as such. Irwin Mitchell Private Wealth looks forward to further clarification over the finer points of the proposed Finance Bill.”
"Once again we see a Chancellor targeting the wrong end of the housing market, and promising to spend a lot of money to little purpose. The government set a target of building 1 million new homes over the five years of this Parliament. A present rate of construction, they will be at least 300,000 homes short of the target. Even if this cash injection delivered an extra 140,000 homes, it would not bridge the shortfall from the target the government is already missing. More likely, measures such as cash for homes etc. will simply further bid up the price of the existing inadequate supply, so much of Mr Hammond's funding will simply transfer money from the taxpayer to the house builders, with little additional housing to show for it. Disappointingly, there was no mention at all of retirement housing. Mr Hammond could have had a far greater effect on supply of housing if he had incentivised the construction of retirement living and care homes. If just half of the elderly people who say they want to downsize their property were to do so, that would release 3,500,000 homes onto the market. That is something like five Parliaments' supply at current rates of construction. The land take for such a construction program will be far less than needed for a comparable supply of ordinary housing and much of it could be on brownfield site instead of on the Greenfields that NIMBYs hold so dear."
“Three months on from the Brexit vote, no formal negotiation has been initiated and it is still unclear what will happen to EU nationals in the UK after Brexit. The intention of Prime Minister Theresa May appears to be that the Article 50 notice will be given in early 2017. Unless a different period is agreed, the UK will then have two years from the date of notifying the European Council to negotiate its exit and the framework for its future relationship with the EU. “Until it leaves the EU, the UK is still a member of the EU and citizens of member states have the right to enter, live and work in the UK on the basis of EU law. The British government has indicated that after Brexit they will be generous to EU migrants who are living in the UK already but also that only EU nationals who are in the UK before a certain date may apply for settlement in the UK. It appears that is to provide against a ‘surge’ of new EU migrants coming to the UK before its exit from the EU, so it is advisable for EU citizens working in the UK to take all steps possible now to safeguard their position. “The best way EU citizens living and working in the UK can protect their status is to apply for permanent residence or a registration certificate showing that they are allowed in the UK. Those EU citizens with permanent residence should also consider naturalisation as a British citizen. This has several advantages over permanent residence as it cannot be withdrawn.”
Brexit will potentially have a huge impact on the people who work in the UK’s financial services industries. Many banks, insurers and fund managers who have large businesses in continental Europe could consider relocating to Paris or Frankfurt, and senior staff will either lose their roles or have to move to another country. Some global investment banks, such as JPMorgan, have said that Brexit would lead to a significant loss of jobs in the UK.
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