HELPLINE: 
How to plan cross-border wealth before retirement
The situation. Norah*, a British woman, and her French husband Nacer* have been living in the UK for the last three decades. They have two children, plan to retire in seven years and relocate to France within three. With £2 million in liquid assets and no other income expected, they want to prepare for tax-efficient drawdown and inheritance planning.
The issue. As UK residents the couple can’t open a French assurance vie, but starting its eight-year fiscal clock is key to unlocking France’s favourable tax regime. After eight years, withdrawals benefit from preferential taxation and even new contributions qualify. To overcome this obstacle they needed to start the fiscal clock before moving.
Cross-border strategy. We recommended a UK-compliant Personal Portfolio Bond (PPB) issued in Luxembourg, which is one of few available since Brexit.
- While the Livingstones remain in the UK, the PPB functions as a UK investment bond, allowing 5% tax-deferred withdrawals and access to top slicing and time apportionment relief.
- When they move to France, it automatically converts into an assurance vie, with the fiscal clock already running.
- Should they relocate to another country such as Spain or Belgium, it adapts to the local equivalent.
- In the event they return to the UK, it reverts to PPB status, with tax due only for UK-resident years.
UK advantages. The PPB offers deferred taxation on gains, top slicing relief to reduce effective tax on encashments and exemption from capital gains tax on underlying investments. Inheritance tax applies only under UK domicile rules, with a £325,000 per individual nil-rate band (or £650,000 per couple).
Takeaway. For clients planning moves to France or elsewhere in Europe, a PPB offers an elegant solution: the fiscal clock starts early and UK tax advantages remain along with a portable structure.