A megayacht offering five-star living and services has been unveiled, promising an alternative way of life for adventurous UHNWs.
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Comprising about 132 residences and 22 guest suites, the 320-metre superyacht Ulyssia is set to make waves as the most exclusive private residential ship community in the world when it launches by the end of the decade.
A floating haven for UHNWs, the Espen Øino International-designed vessel will traverse the globe, following selected itineraries that will range from European city breaks to exploration of some of the most remote locations on Earth.
Residents can jump on and off when they choose: they may stay for weeks, or opt for years-long or never-ending journeys. Ulyssia Residences AG CEO Alain Gruber describes the concept as ‘travelling the world from the comfort of your home.’
Ulyssia isn’t the first of its kind; The World, currently the largest private residential yacht, with 165 residences, was launched in 2001 and set the benchmark for luxury residential boat living. Now Espen Øino International has set its sights on the ‘next generation’ vessel.
Five-star living at sea
The residences on Ulyssia range from 113 sq m (1,216 sq ft) to 982 sq m (10,570 sq ft), and are available in one- to six-bedroom configurations, including penthouses and family duplexes. Each home boasts reception rooms, open-plan kitchens, uninterrupted sea views, and private terraces. Prices start from €9.5 million with a 3-5 per cent service charge, which covers a food and beverage allowance, and all maintenance and operating costs.
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Additionally, there will be a spa, a fitness, and wellness facility, indoor and outdoor pools and numerous terraces and sundecks. There are also plans for sports and recreational facilities, including padel and pickleball courts.
The interior design is led by FM Architettura, with contributions from prominent designers such as Jean Michel Gathy and rock-star turned interior designer Lenny Kravitz.
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Residences are largely ready for occupancy – guests can choose to stamp their own personality with their personal effects and artworks – but buyers can choose from a selection of designs by eight world-class interior designers or appoint their own team to create a personalised space.
The principal investor is Frank Binder, who has also purchased the first penthouse on board. The development team includes highly experienced professionals from top maritime and hospitality companies such as The World Residences at Sea, Seabourn, and Ritz Carlton.
Fiscal nomad tax pitfalls
Yet while the prospect of being a seafaring nomad might be tempting for UHNWs, there could be tax implications.
Robert Brodrick, a Spear’s Top Flight tax lawyer and chair and partner at Payne Hicks Beach, says tax jurisdiction is determined not by how many days people spend at sea, but how many days they spend on dry land.
The company behind Ulyssia recommends people seek professional advice from a tax lawyer. It says it expects residents to spend an average of four, non-consecutive, months a year on the boat. If residents were to spend the remaining eight months of the tax year in the UK, Brodrick explains, they would remain UK resident under the statutory residence test.
‘For people who are able to limit the number of days that they spend in the UK each tax year, spending four months on the boat, under three months/90 days in the UK and a similar amount of time in three or three other countries, it should be possible to become a ‘fiscal nomad’ i.e resident nowhere for tax purposes,’ he explains.
The tax rules differ from country to country. ‘If you are a US citizen, you will be taxed on a worldwide basis in the US regardless of how much time you spend on the boat.’
Claire Randall, a Spear’s 500 lawyer at Farrer & Co, said HNWs would ‘need to consider their residency position in relation to all relevant jurisdictions’.
‘This is likely to include the country they were resident in before moving onto the yacht, any other countries where they have property and other connections (such as family and business) and where they spend time. Time spent ‘at sea’ where the waters belong to a particular country may well count as time spent in that country. For example, midnights spent in British waters are likely to count as days spent in the UK for the UK’s statutory residency test.
‘It is possible that more than one country will try to argue that the individual is resident there. In that case, they would need to look to the tax agreements between the countries to avoid paying tax in multiple countries. Records of time spent and connections with each country will be important as will taking tax advice in all relevant jurisdictions.’
With a backdrop of global uncertainty, the tax situation remains unknown at the time of Ulyssia’s projected launch – although not, Brodwick, necessarily negatively for UHNWs.
‘The change could, in fact, be beneficial particularly as regards Inheritance Tax. At the moment your exposure to Inheritance Tax is largely governed by your domicile status, and if you are UK domiciled, your worldwide estate will be subject to UK Inheritance Tax when you die subject to reliefs and exemptions.
‘To lose your UK domicile status, at the moment you have to leave the UK and reside in another country as an inhabitant of that country/state, with the intention of remaining there permanently or indefinitely.
‘By doing this you will replace your UK domicile status with a domicile of choice in the new country/state. Moving to a residential yacht will not be enough to displace your UK domicile status for Inheritance Tax purposes, but if ‘domicile status’ is abolished for tax purposes following the general election, it may be possible to escape UK inheritance tax simply by becoming non-UK resident.’
