The majority of Ravi’s practice is for international clients. His clients are normally professional fiduciaries, wealthy individuals and their advisers. Ravi advises on a broad range of subjects which tend to centre around UK tax law and the law governing trusts and other wealth-holding structures. His most common areas of advice include:
- tax planning for clients who are moving to or leaving the UK, to minimise both UK and foreign taxes;
- determining an individual’s UK tax residence and domicile status under UK law and the impact this has for UK tax purposes;
- using offshore trusts, foundations and companies to hold personal wealth and business assets;
- establishment, administration and taxation of UK investment companies;
- advising on UK succession laws and how conflicts with foreign succession laws can be resolved; and
- the application of double taxation agreements to an individual’s affairs.
- Advising an ultra-high net-worth non-UK domiciled individual on his immigration to the UK, and subsequently working as part of a small team of advisers (including two leading QCs, magic circle offshore lawyers, and leading Australian lawyers/tax advisers) to establish a Guernsey-based operating structure for his global business, the turnover of which is in the hundreds of millions of pounds.
- Working as part of a team, including a leading QC and US tax experts around the world, advising an ultra-high net worth Russian businessman prior to his move to the UK. This included the restructuring of both personal wealth and business structures to minimise UK tax liabilities. This included advice on the laws of “central management and control” and the restructuring of Liechtenstein foundations into trusts. A particular highlight was the restructuring of two “superyachts” through a complex leasing scheme and the import and registration of a private jet to minimise VAT liabilities.
- Advising a prominent member of a Middle Eastern royal family on the restructuring of property interests in London, where the annual tax on enveloped dwellings, inheritance tax and various capital gains tax regimes were all in point.
- Acting in the administration of a complex cross-border estate of a ultra-high net worth Ugandan domiciled, Dubai-resident businessman, who held most of his assets through a BVI holding company, had interests in mining and hotel businesses in the Middle East, who died with an incomplete will which purported to create a trust, and whose heirs were all resident and deemed domiciled in the UK.
- Advising a Middle Eastern billionaire on structuring his £40m UK-based art collection and c.£40m worth of UK residential property. This included the design of a Jersey private trust company, in collaboration with Jersey-based fiduciaries, lawyers and bankers. The primary motivations for this structuring were asset protection, succession planning, control and continuity of family governance.