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Sara Morgan


Sara specialises in advising on personal taxation, trust and estate planning for individuals and trustees in the UK and overseas. She has extensive experience advising high net worth and ultra high net worth individuals and trustees on UK tax and trusts matters, particularly where there is an international dimension.

Many of Sara’s clients are either non-UK domiciled or non-UK resident and her work involves advising on not just the UK tax aspects of their personal wealth planning but also on family succession issues and the preservation of family wealth. She has considerable experience of the establishment and running of complex family wealth structures, including private trust companies.



Sara takes a client-focused approach to her work, seeking first to understand the aims and intentions of clients and then to consider how those can be achieved in an efficient and effective manner. Sara is able to provide a tax and succession advice to high net worth and ultra high net worth international individuals, working together with the client’s wider team of advisers and trustees to provide a cohesive approach which takes into account the client’s broader concerns and intentions.

Sara joined Payne Hicks Beach as a Partner in the Private Client team in November 2022, arriving from Fieldfisher LLP (where she had moved in 2019 with the Linklaters trusts team). Sara qualified as a Solicitor in 2004, became a member of STEP in 2006 and a Chartered Tax Adviser in 2009. In the course of her career, Sara has worked in other highly-ranked London Private Client teams, including Withers and Forsters.


Member of the STEP City of London Branch Committee.

Society of Trust and Estates Practitioners (since 2009)

Chartered Institute of Taxation (since 2006)

Elected Member of the STEP England and Wales Regional Committee (seat takes effect from January 2023 as representative of the STEP City of London Branch)

· Pre-residence advice for individuals considering becoming UK resident, including the application of the statutory residence test, the remittance basis of taxation and the key concerns around preparation for UK residence to minimise remittances and structure assets effectively for the future. Advice provided has included the application of the business investment relief rules to potential investments.

· Advice on the issues to be considered when leaving the UK and becoming non-UK resident for tax purposes, including the application of the statutory residence test in this context, a consideration of the implications of the ‘tax tail’ applicable to deemed domiciled individuals and the caution to be taken in the years following departure.

· Advice on the application of the temporary non-residence rules for capital gains tax and remittance purposes for individuals leaving the UK who may return in future years.

· Advice on the domicile status of individuals for UK purposes and the implications of long term UK residence.

· Advice on the application of the 2017 offshore trust rules, including the care needed to avoid tainting protected trusts and the implications of tainting when it occurs. Sara recently pursued a non-UK trustee for professional negligence in failing to prevent the tainting of a trust.

· Advice on court action to vary both UK and non-UK trusts.

· Advice on succession and UK inheritance tax issues (including those arising in respect of UK residential property) and the potential for mitigation of those issues in the context of international individuals and trusts. This may include the consideration of the potential use of family investment companies as part of the restructuring of family succession arrangements. Sara advises and manages implementation of appropriate restructuring to minimise tax exposure, including the drafting of all relevant wills and trust documents.

· Advice on general ongoing non-UK trust matters, including the transfer of trusteeships, deeds of appointment, loans, sale and purchase agreements. Recent advice has included the restructuring of a large and complex private trust company structure to meet the changing needs of the family and intentions of the settlor.

· Reviewing trust structures for UK tax issues and any updating needed in light of the changes to the tax regime or family situation.

· Advice on the application of the Trust Registration Service and Register of Overseas Entities.