Residence & Domicile
Tax planning for non-domiciliaries, expatriates, and internationally mobile individuals. Advice on UK departure, remittance basis, and the Finance Act 2025 extended deemed domicile rules.
Daniel Feingold is one of the UK's most experienced specialist tax barristers, advising solicitors, accountants, corporates, and high-net-worth individuals on the full spectrum of UK and international tax matters from Burnell Chambers, Middle Temple.
Daniel advises on the full range of complex UK and international tax matters, instructed by leading law firms, accountancy practices, and directly by clients across corporate, private client, and contentious work.
Tax planning for non-domiciliaries, expatriates, and internationally mobile individuals. Advice on UK departure, remittance basis, and the Finance Act 2025 extended deemed domicile rules.
Representing clients in tax investigations, enquiries, and disputes with HMRC, including Code of Practice 9, offshore disclosure, and Tax Tribunal appeals.
Tax advice on mergers, acquisitions, demergers, management buy-outs, company reconstructions, and pre-sale planning to maximise tax efficiency.
International transfer pricing structuring, intellectual property rights management, and cross-border royalty arrangements for multinational groups.
Design and implementation of EMI, CSOP, SIP, unapproved share options, Employee Ownership Trusts, and Employee Benefit Trust structures.
Offshore trusts, foundations, and international holding structures. Advice on offshore disclosure obligations and double taxation treaty planning.
CGT planning on disposals of businesses, shares, and property. Business asset disposal relief, holdover relief, rollover, and offshore gains.
IHT mitigation including BPR, APR, trust planning, and advice for those leaving the UK under the extended deemed domicile rules.
Advice on off-payroll working rules, IR35 status determinations, and structuring for contractors and their intermediary companies.
Daniel Feingold is a barrister and specialist in tax law with over 30 years' experience at the highest levels of the profession. Called to the Bar, he holds a business degree and has built an exceptional career spanning the UK's leading international accountancy and law firms.
Before joining Burnell Chambers, Daniel was Senior Partner of Stratax LLP, a niche tax law firm he founded (initially as Strategic Tax Planning), following senior roles at BDO Stoy Hayward, Dechert LLP, and Grant Thornton. He has developed particular expertise in residence and domicile planning, international tax structuring, and complex HMRC disputes.
His pragmatic, commercially minded approach — focused on delivering tangible outcomes rather than theoretical positions — has made him a trusted adviser to solicitors, accountants, corporate clients, private equity and venture capital firms, wealth managers, and high-net-worth individuals.
Daniel has appeared on BBC Radio 4, contributed extensively to Mondaq, and delivered seminars across the profession on leading tax issues of the day.
"Getting out of the UK tax net and selecting the right favourable tax jurisdiction is actually quite challenging — the detail matters enormously."
— Daniel Feingold, Tax Journal
Daniel's practice spans landmark residence disputes, complex offshore structures, and leading published commentary on UK tax reform.
Tax residence dispute in which the Upper Tribunal held that the taxpayer retained UK residence despite claiming Belgian residency — his "centre of vital interests remained in the UK." Daniel has provided expert commentary on the implications for internationally mobile individuals.
Tax ResidenceDaniel has critiqued the extension of the deemed domicile period from three to ten years for those leaving the UK as "extremely punitive and in practice unenforceable," advising clients on optimal exit planning under the new regime.
Domicile · PolicyAdvising UK-born and domiciled clients seeking to leave the UK tax net following IHT regime changes — selecting favourable jurisdictions while navigating statutory residence tests, treaty provisions, and anti-avoidance rules.
International PlanningRegularly published and cited on non-dom reform, remittance basis planning, and the implications of UK tax policy changes for high-net-worth internationally mobile clients and their advisers.
Non-Dom · PublicationsExtensive experience advising on tax aspects of company reconstructions, MBOs, Employee Ownership Trusts, and bespoke share incentive arrangements for PE-backed and owner-managed businesses.
Corporate · M&AActing for clients in high-value HMRC investigations and appeals, including residence disputes, offshore disclosure matters, and challenges to HMRC's application of anti-avoidance legislation.
Litigation · HMRCDaniel is a recognised voice on UK and international tax policy, contributing regularly to the profession's leading journals, media outlets, and CPD programmes.
Profile interview on non-dom planning, Finance Act 2025 implications, and the current challenges of advising clients who want to leave the UK tax net.
Invited contributor on BBC Radio 4 covering UK tax policy, international tax planning, and the changing landscape for high-net-worth individuals.
Regular author covering non-dom reform, offshore structuring, HMRC enforcement trends, double taxation, and international tax planning strategies.
Delivering seminars to law firms, accountancy practices, and wealth management teams on current tax issues, case law, and planning strategies.
Daniel accepts instructions from solicitors, accountants, and other regulated professionals, as well as directly from clients under Direct Access rules. Complete the form and the clerks will respond within one business day.
Monday – Friday · 9:00am – 6:00pm