Paul Davidoff

Partner

+44 (0)20 7814 1268 pdavidoff@kingsleynapley.co.uk

Our People

Paul advises UK and international individuals, families, trustees and beneficiaries in relation to a wide range of Private Client matters, including taxation, UK and offshore trusts and other asset-holding structures, as well as both UK and cross-border wills and succession planning and personal tax planning.

He can frequently be found discussing the ins and outs of the “domicile” rules and the UK’s “statutory residence test” and their implications for individuals, companies and trusts. A common issue that Paul is asked about is the ownership of UK properties, including where that is via a trust and/or a company.

Recently, he has been focusing on advice to those whose UK tax position has been affected by the changes to the taxation of those with UK connections and the trusts that they are involved with, including expats who are wanting to return to the UK and those not from the UK who are considering a move here.

Paul has spoken at both the STEP Cayman Islands and STEP Malta conferences on matters relating to UK taxation for those coming to and those leaving (or having already left) the UK.

Paul joined Kingsley Napley in 2025 from private client boutique New Quadrant Partners where he had been a partner since 2018. He is a member of STEP and has completed the STEP Advanced Certificate in “UK tax for international clients” with distinction.

Paul has been recognised in Spear’s 2025 Tax & Trust Advisers Index, Citywealth, Lexology (formerly Who’s Who Legal), Best Lawyers and various other listings over the years.

+44 (0)20 7814 1268 Connect on LinkedIn pdavidoff@kingsleynapley.co.uk

Publications

Private wealth, family offices and the next phase of digital assets, Citywealth, February 2025
Cayman Islands: A Premier Global Hub for Wealth, Innovation, and Family Office Migration, Citywealth, February 2025

Recent Work

Helping beneficiaries of offshore trusts

The UK has a complex set of rules which govern how the UK taxes offshore trusts (ie “trusts which are not resident in the UK”).Paul has helped numerous settlors, trustees and beneficiaries to navigate these rules with confidence and manage their UK tax compliance in a tax efficient manner.

On several trusts, Paul has advised about how the taxation of trusts has changed following the Finance Act 2025 and how to manage UK tax exposure in the coming years.

Helping a long-term expat with his tax and succession planning on his return to the UK

Paul advised this HNW client understand how best to organise his finances in the light of his imminent return to the UK, what sorts of investments would be more tax-efficient and whether / when his investments should be brought to the UK. The primary aim was to minimise his liability to income tax, capital gains tax and inheritance tax.

Paul worked with the client’s investment adviser in the Cayman Islands to ensure that this adviser was aware of the UK tax limitations on the client’s investments. He also arranged a new will to cover assets in three different countries – a will that would provide protection for his wealth from the next generation (until the next generation are old enough) and Lasting Powers of Attorney to be used in the UK, if needed.

Advising long-term expat who may still have a UK domicile

Paul advised an expat who left the UK in the 1980s to work as a lawyer in the Caribbean and then married a Canadian. They have an adult child who lives in the UK. They also own a property in London and hold substantial funds in the UK. Until April 2025, there remained a risk that HMRC would argue that this client was still domiciled within the UK, which could have caused significant inheritance tax liabilities for the family. They were also worried about the tax consequences of inadvertently or unavoidably becoming UK resident.

Paul explained the opportunities provided by the 2025 tax regime and how these changes will affect (and, in many ways, improve) the family’s tax position, setting out the parameters of maintaining the most tax-efficient arrangement of their finances and property ownership and the risks that remain for them even under the new rules.

Advising the beneficiaries of a complex foreign estate with assets in the UK

Paul was asked by a Maltese lawyer to provide urgent assistance with the estate of a wealthy Maltese business owner who died owning a UK investment portfolio and a house in London which was owned through a foreign company.

Paul advised how the family would be able to re-arrange how the estate was inherited in order to benefit from the “spouse exemption” from inheritance tax, so far as possible, and prepared the necessary documentation to achieve this in a way which tied in with the Maltese succession law and estate administration.

He also advised about the UK tax consequences of the property ownership arrangement and the outstanding UK tax reporting required in connection with this.