Heritage & Taxation 2026

BULLETIN FOR PROFESSIONAL ADVISERS 2 026

Sell with Christie’s Private & Iconic Collections CONTACT Amelia Walker awalker@christies.com +44 (0) 20 7389 2085

BARRY HUMPHRIES: THE PERSONAL COLLECTION Sale total: £4,627,224 London, February 2025

christies.com

Index 3 Editorial Margarita F-A Chiclana 5 A Painting in Focus Ruth Cornett 7 America at 250: We the People, We the Icons. How History and Pop Culture Converge at Auction Peter Klarnet 14 Worn Histories: Jewellery, Identity and Lasting Value Henry Bailey 24 Exporting Works of Art: Binding offers Ruth Cornett 28 Christie’s Education: Untangling the Complexity of the Art Market for a Global Audience Ted Sandling 32 Matters of the Art: a solicitor’s perspective on estate planning Arthur Byng Nelson

Christie’s Bulletin for Professional Advisers

EDITORIAL In this issue, we reflect on a point of convergence

A related dynamic is explored in Worn Histories:

between history and the present, where objects

Jewellery, Identity and Lasting Value. As Henry

are increasingly understood not only for what they

Bailey outlines, jewellery occupies a distinctive

are, but for the stories they carry and the contexts

place within the collecting landscape, combining

in which they exist. Across collecting categories,

craftsmanship and rarity with an immediate

a clear thread emerges in the form of a growing

personal dimension. Its enduring appeal lies not

sensitivity to narrative, provenance and meaning,

only in material quality, but in the associations it

and to the ways in which these qualities shape both

holds and the histories it reflects.

value and engagement.

Alongside these market perspectives, this issue Margarita F-A Chiclana Senior Coordinator Heritage and Taxation Advisory Service Christie's, London mfachiclana@christies.com

This issue shines a spotlight on our forthcoming

also considers the frameworks that govern the

Old Master Paintings Evening Sale, led by two

movement and stewardship of works of art. Ruth

superlative works by Jan van Huysum, celebrated as

Cornett’s analysis of the UK export licensing

the ‘Phoenix of Flower Painters’ (pages 14-15), and

regime provides a clear overview of the operation

offers an intimate look at Sir Thomas Lawrence’s

of binding offers. This is followed by Ted Sandling’s

portrait of the 1st Duke of Wellington, reflecting the

contribution

subtle balance between public image and private

considers how knowledge and access support

presence that defines its lasting appeal.

more confident and informed engagement with

on

Christie’s

Education, which

the art market.

Peter Klarnet’s America at 250: We the People, We the Icons offers a considered view of this shift.

Arthur Byng Nelson’s Matters of the Art concludes

Drawing on two recent Christie’s sales, this article

this strand with a perspective grounded in estate

presents a market in which historical documents,

planning, addressing the legal and practical realities

works of art and cultural artefacts are linked by

of managing collections across jurisdictions and

their ability to articulate shared histories. The

generations.

results demonstrate a sustained appetite for objects that act as touchstones, grounding collectors in

Taken together, the contributions point towards

moments that continue to resonate.

a market shaped as much by interpretation as by transaction. Across categories, there is a discernible

Within this context, rarity alone no longer defines

shift towards objects that carry meaning alongside

significance. It is the combination of narrative,

value. For advisers, this requires an approach that

historical importance and provenance that gives

recognises both the technical and financial aspects

such objects their particular presence. The success

of a collection, as well as its cultural and personal

of these sales reflects a broader movement towards

significance.

collecting that is informed by connection as much as by connoisseurship.

Cover

Opposite

Copyright

Comments and Suggestions

Christie’s

Note

JOHN DEARE (1759-1798) Queen Eleanor sucking poison from the wound of King Edward signed and dated 'I DEARE FACIEBAT ROMAE/1790' (lower centre) Carrara marble bas-relief 86 x 99cm.

Executed in 1790

DOMENICO FETTI (1589-1624), A Bacchanal Carrara marble bas-relief 86 x 99cm. oil on panel painted circa 1618-1622 68.6 x 45.7cm.

© Christie, Manson and Woods Ltd., and contributors 2026.

No part of this publication may be reproduced, stored in a retrieval system or transmitted by any form or by any means, electronic, mechanical, photo-copying, recording or otherwise without the prior written permission of Christie’s.

If you would prefer to receive future Bulletins by email or in PDF format, or if you have any comments or suggestions regarding the publication, please email lromanelli@christies.com

8 King Street, London SW1Y 6QT Tel: +44 (0) 20 7839 9060

All views expressed in this Bulletin are a matter of opinion only. Neither Christie’s nor contributors accept any liability whatsoever in relation to the accuracy of the opinions given.

Accepted by HM Government in lieu of Inheritance Tax from the Estate of Jacob, 4th Baron Rothschild and allocated to Victoria & Albert Museum, London.

Accepted by HM Government in lieu of Inheritance Tax from the Estate of the Late Lavinia Davies, and allocated to the Ashmolean Museum, Oxford.

3

Christie’s Bulletin for Professional Advisers

A PAINTING IN FOCUS:

Sir Thomas Lawrence’s Portrait of the 1st Duke of Wellington

The art of portraiture is perhaps the most

portrait confirms this peak behind the mask of fame,

challenging for any painter. In essence the greatest

Harriet Arbuthnot writing in her diary recorded her

portraits are a private conversation between

view thus: ‘All other pictures of him depict him as a

the artist and sitter recorded for the viewer. To

hero this portrait has all the softness and sweetness

capture the likeness and spirit of the sitter so that

of countenance which characterises him when he is

both contemporaries and posterity recognise the

in the private society of his friends’

image and the personality is a demanding task but the greatest examples continue to resonate

This picture remained with the Arbuthnot family

long after completion.

until sold at Christie’s in 1878. It was acquired by the 5th Earl of Rosebery (1847-1929) and remained

Ruth Cornett, CTA TEP Senior Director, Heritage and Taxation Advisory Service Christie's rcornett@christies.com +44 (0) 20 7389 2102 Prior to joining Christie’s, Ruth Cornett worked as a tax adviser in a number of professional firms in the City and the West End of London. After training as an art historian and working as a curator in the V&A, Ruth changed careers in 1992, studying law and qualifying as a Chartered Tax Adviser (CTA) in 1998. Ruth has advised a broad spectrum of clients on a range of tax matters with a particular emphasis on capital gains tax, inheritance tax and income tax.

To consolidate her expertise in these areas, Ruth qualified as a Trust and Estate Practitioner (TEP) in 2008. Ruth lectures frequently for Christie’s Education and STEP on tax and heritage matters, has contributed to leading publications in this field and sits as an observer on the Tax and Political Committee of Historic Houses (HH).

This summer at Christie’s the celebrated portrait of

in that family until sold, again at Christie’s, in 1939,

the 1st Duke of Wellington executed by Sir Thomas

when it passed to the collection of W. U. Goodbody.

Lawrence will be offered for sale in the Old Masters

It remained in that family until sold at Christie’s in

Evening Sale. The portrait was commissioned

2006. In 2026 it returns to Christie’s for sale once

in 1820 by Wellington’s close friend, Charles

more and awaits the next owner to eavesdrop the

Arbuthnot (1767-1850), a diplomat and politician,

conversation between Lawrence and Wellington.

whom Wellington had first met in Paris in 1814. The

Do come to experience that for yourself.

portrait was unveiled at the Royal Academy in 1822 to immediate acclaim, and mezzotints of it were chosen as gifts by Wellington to his friends and admirers, thus ensuring its popularity and fame.

OLD MASTERS EVENING SALE Lawrence painted Wellington’s portrait eight times

30 June 2026 | 6.30pm | London

but this image is perhaps the most insightful, showing the personal side of the experienced

VIEWING TIMES:

soldier in civilian clothes, rather than military dress,

Friday

June 26

9.00am - 5.00pm

with only the insignia of the Order of the Golden

Saturday

June 27

12.00pm - 5.00pm

Fleece, awarded after the victory over Napoleon

Sunday

June 28

12.00pm - 5.00pm

in the Peninsular War, hinting at his extraordinary

Monday

June 29

9.00am - 5.00pm

achievements. A contemporary description of the

Tuesday

June 30

9.00am - 2.00pm

OPPOSITE: SIR THOMAS LAWRENCE, P.R.A. (1769-1830) Portrait of Arthur Wellesley, 1st Duke of Wellington, K.G., K.B., M.P. (1769-1852), bust-length, in civilian clothes with a military cloak, wearing the insignia of the Order of the Golden Fleece with inscription 'An admirable likeness. Charles Arbuthnot 13[?]th...

1821[?]' (on an old handwritten label attached to the reverse) oil on unlined canvas 30 x 25½ in. (76.2 x 64.8 cm.)

5

Christie’s Bulletin for Professional Advisers

The auctioneer and Deputy Chairman, Tash Perrin, knocked down the most expensive guitar ever sold at auction, David Gilmour's 'Black Strat' for $14,550,00 (with buyer's premium) after 21 minutes of bidding

6

America at 250: We the People, We the Icons. How History and Pop Culture Converge at Auction

America at 250: We the People, We the Icons.

How History and Pop Culture Converge at Auction During the first quarter of 2026, Christie’s has

We the People was a live saleroom auction,

witnessed one incredible sale after another - most

featuring 44 lots from various owners. The tightly

especially in the worlds of American Art, Old Master

curated sale weaved a thread through the history

Paintings and Asian Art. This plethora of strong

of the United States from its foundations in the

sales was complimented by two significant auctions

eighteenth century to the twenty-first, featuring a

featuring more eclectic, cross-category objects, that

wide variety of objects, including books, documents,

were met with a resounding positive response from

broadsides, letters, paintings, decorative arts,

our clients and resulted in two record-breaking

photographs, flags and banners. With an aggregate

auctions, first on 23 January with our masterpiece

low estimate of $17,204,000, the sale realised a total

sale of important Americana, We the People:

of $35,562,465.

America at 250 and then again in early March with Peter Klarnet Vice President, Senior Specialist, Americana, Books & Manuscripts Christie’s, New York Peter joined Christies in 2016 after twenty years working with manuscript Americana, spending the first portion of his career cataloguing for, and later managing, a Connecticut auction house specializing in historical autographs. In 2005 he left that firm to pursue opportunities as a consultant, agent and dealer. Although his primary interests centre on early America, especially the American Revolution and Early Republic, Peter has appraised, catalogued and sold a wide range of material from the 17th to the 20th centuries.

Since joining Christie's, Peter has worked with many important collections including the papers of the Marquis de Chastellux, The Private Collection of President and Mrs. Reagan, The Findlay-Wright Papers, the Roger Judd Collection of American Historical Autographs, the Louisiana Purchase Collection of A. J. Tullock, The Collection of Lee Bouvier Radziwill, The Private Collection of William S. Reese, The Birth of Wikipedia, The Papers of Richard N. Goodwin, and most recently, DJ Kool Herc and the Birth of Hip Hop and The Collection of André Leon Talley.

Peter holds a B.A. in History from Antioch College, and a M.A. in History from the University of Delaware with a certificate in museum studies. He has curated several exhibits including a major exhibition at Federal Hall in New York celebrating the bicentennial of the birth of Abraham Lincoln in 2009.

the incomparable memorabilia offerings in The Jim

Many of the top lots marked important moments in

Irsay Collection held in a series of sales between

American history, including a broadside edition of

12 and 17 March. Combined, the auctions achieved

the Declaration of Independence printed in July 1776

nearly $130,000,000 in sales.

($5,687,000); the penultimate draft of the United States Constitution edited by delegate Rufus King at

Those strong results were no accident. They were

the 1787 Convention in Philadelphia ($7,395,000); an

the result of considered planning, strong teamwork,

important copy of the Emancipation Proclamation

coupled with Christie’s ability to reach and engage

signed by Abraham Lincoln ($6,785,000); a flag

new and existing clients. That hard work was

recovered from the Custer battlefield ($2,515,000),

bolstered by increasing collector interest in objects

and the contract that formed Apple Computer on

that provide symbolic touchstones to our shared

1 April 1976 ($2,515,000). All five achieved prices

popular culture ranging from important historical

well over their low estimate and in the first three

documents and literary manuscripts, to instruments

cases, exceeding the high estimate. The results

used by musical icons, and to clothing donned by

signal a strongly growing interest in this collecting

legendary sports figures. These objects tend to do

area over the past decade. The price for the 1776

well at auction not only because they might mark

broadside of the Declaration of Independence,

important moments in history and/or popular

believed to be printed in Exeter, New Hampshire

culture, quite often they are coupled with stories

in mid-July 1776, is, at the time of writing, a world

that engage collectors.

auction record price for any copy save for the first printing produced by John Dunlap in Philadelphia on the night of 4 July 1776. The last time Christie’s sold a copy of the Exeter broadside, it brought only $930,000 in 2021.

7

Christie’s Bulletin for Professional Advisers

8

America at 250: We the People, We the Icons. How History and Pop Culture Converge at Auction

These impressive results for historical documents and artifacts were complimented by several important pieces of American art from vastly different eras, with the most impressive results achieved for pieces with compelling stories or provenance underlying the objects. First and foremost was Gilbert Stuart’s portrait of George Washington that our exceptional research has revealed was commissioned by James Madison. The work, offered by Clarkson University, was marketed under the title: “A President’s President,” linking the two founders and marking the first time a portrait of Washington owned by another person who held the highest office in the land had ever come to sale. Against a $500,000 – 1,000,000 estimate it achieved $2,881,000: the highest price ever paid for the “Atheneum Type” (more commonly known as the “dollar bill” portrait). Meanwhile, Grant Wood’s diminutive pencil study for his painting American Gothic, accomplished on the reverse of an envelope, brought another smashing result. Measuring a little over three by four inches, this, the only study known for his most iconic work, sailed well past its pre-sale estimate of $70,000 – 100,000 to achieve $584,200.

These top offerings were just the beginning, and the impressive results not merely reserved for pieces made by or associated with white men. A signed volume of the famous enslaved black poet, Phillis Wheately, estimated at $30,000 – 50,000 brought $120,650; while Ernie Barnes’s painting, The Hall realised $304,800 against its $150,000 – 250,000 GILBERT STUART (1755-1828) George Washington (Athenaeum-Type) oil on canvas 29½ x 24⅛ in. (74.9 x 61.3cm.)

Commissioned in 1804.

pre-sale estimate. And an impressive example of a Navajo Sandpainting Rug brought $101,600 (estimate $20,000 – 30,000).

Overall,

the

sale

underscored

the

growing

enthusiasm for quality pieces of Americana as we approach the 250th anniversary of the Declaration of Independence this summer. Additionally, the results make very clear that this upswing is not limited to objects associated with the American Revolution and the nation’s founding. With other major anniversaries approaching over the course of the next decade, we fully expect collector interest to continue to drive this market for the foreseeable future.

Opposite: Rufus King’s copy of the Committee of Style Draft of the United States Constitution

9

Christie’s Bulletin for Professional Advisers

ORIGINAL TYPESCRIPT SCROLL FOR THE MONUMENTAL FIRST DRAFT OF ON THE ROAD, THE DEFINITIVE BEAT GENERATION NOVELKEROUAC, JEAN-LOUIS LEBRIS DE ("JACK") (1922-1969)

10

America at 250: We the People, We the Icons. How History and Pop Culture Converge at Auction

THE JIM IRSAY COLLECTION, 11-17 MARCH 2026

Held in four auctions, including three live sessions

Jack Kerouac’s original draft scroll for On the Road

and one online sale, the unsurpassed collection

in our New York auction rooms for what was then

of memorabilia assembled by the late owner of

the world record price paid for a modern literary

the Indianapolis Colts, Jim Irsay proved a roaring

manuscript at $2,426,000 (New York, 22 May 2001

success. With an aggregate low estimate of

lot 307). When it returned to Christie’s, it attracted

$26,626,400, the sale achieved an astounding

multiple bidders who drove it up to $12,135,000,

$94,402,353, or more than four times the pre-sale

setting the same world auction record once again.

estimate. An evening sale subtitled Hall of Fame kicked things off on 11 March and featured his

Yet those records are just the beginning. Some of

most iconic pieces: 44 lots ranging from guitars

the other breathtaking results from the sale included

with celebrity provenance to important literary

Jerry Garcia’s guitar, “Tiger,” custom built especially

manuscripts and nearly everything in between. The

for him in 1979, which brought $11,560,000.

12 March session (Icons of Pop Culture) featured

Other highlights included Kurt Cobain’s Fender

102 lots including celebrity-associated musical

Mustang used in the video for “Smells Like Teen

instruments, song lyrics, important letters and

Spirit” ($6,907,000); the 1939 Martin acoustic Eric

documents, as well as sports and entertainment

Clapton used to play “Layla” on MTV Unplugged in

memorabilia. The 13 March session (Icons of Music)

1992 ($4,101,000); not to mention the other David

included 78 lots of fine, vintage guitars. The sales

Gilmour associated guitar: his 1969 Martin he used

concluded with an online selection of 116 lots of

in the recording of “Wish You Were Here,” which

guitars, autographs, books and even vintage Soviet

fetched $2,393,000. (Mr. Irsay purchased that same

spyware, a testament to Mr. Irsay’s eclectic taste.

Martin in the 2019 Gilmour sale for $1,095,000).

Those impressive numbers were led by Mr. Irsay’s

While guitars led the sale records, the sale also

vast musical instrument collection that featured

set world auction records for a trumpet (a Martin

some of the most famous and iconic instruments

Committee Trumpet owned by Miles Davis,

that have come to market in the past three decades.

$1,651,000); a saxophone (John Coltrane’s Yamama

Most notable among these was David Gilmour’s

Nippon Gakki alto saxophone, $431,800); and a

famous 1969 black Stratocaster guitar on which

piano (John Lennon’s, $3,247,000). Ringo Starr’s

he played on stage for many years and was used

first set of Ludwigs established a record for a set

on his most recognisable recordings through Pink

of drums at $2,393,000, while the bass drum head

Floyd’s most productive and impactful years.

bearing The Beatles’ logo that appeared before

When Mr. Irsay first purchased this guitar in 2019

millions of viewers on the Ed Sullivan Show in 1964

at the David Gilmour sale in New York, the guitar

brought even more, realising $2,881,000. Important

set a world record for the price paid for a guitar

manuscript song lyrics also performed extremely

at auction. When that guitar appeared yet again

well including Bob Dylan’s manuscript for “The

on the evening of 11 March, it sold for over $14

Times They Are A-Changin’” ($2,515,00), and Paul

million reclaiming that record following a 21-minute

McCartney’s handwritten lyrics used in the studio

bidding war. Similarly, in 2001, Mr. Irsay purchased

when recording “Hey Jude” ($1,016,000).

11

Christie’s Bulletin for Professional Advisers

While music-related items led the sale results,

with a focus on a broad sweep of American history

other important pieces also brought impressive

and the latter a single-owner collection with a focus

numbers. Sports memorabilia pieces included

on popular culture, they are quite similar for several

jockey Ron Turcotte’s saddle rode with Secretariat

reasons. First, both sales were composed of objects

to win the Triple Crown in 1973 sold for $1,524,000;

across a range of traditional collecting categories.

Muhammad Ali’s first robe to feature his name after

This helped drive overall interest in the sales and

he had changed it from Cassius Clay and used in

led to cross-category interest. Secondly, the pieces

his second fight with Sonny Lison in 1965 realised

in both sales offered were of the highest quality,

$444,500; and the jersey worn by Wane Gretzky

often coupled with background stories our clients

when he scored his 500

career goal scored

found engaging. Finally, they are similar in that

$952,500. Hollywood was also well represented

they both captured a growing market for “non-art”

in the form of one of Sylvester Stallone’s drafts for

collecting categories, and in particular, it speaks

the film, Rocky ($508,000); one of “Wilson” prop

to the growing appetite among collectors for

volleyballs used in the film, Castaway starring

objects that tell our collective stories: whether that

Tom Hanks ($101,600); as well as a “Golden Ticket”

be a nostalgic look at our personal history, or an

produced for the classic 1971 Gene Wilder film Willy

appreciation of our historical past.

th

Wonka & the Chocolate Factory ($203,200).

Conclusion Taken together, We the People: Perhaps the chief takeaway from the sales is that

America at 250 and The Jim Irsay Collection

Jim Irsay collected for all the right reasons. He

exemplify Christie’s unique ability to situate objects

bought things because they appealed to him as

of history and popular culture within a compelling

they brought him closer to those individuals he

market and intellectual framework. While one sale

most admired and the times in history that evoked

traced the evolution of American identity through

his passion. The collection was as much about

foundational documents and fine art, and the

the objects themselves as they were about the

other celebrated the cultural power of music, sport,

person who collected them. This resonated with

literature and film, both auctions demonstrated that

our clients who helped make it the most valuable

collectors are increasingly motivated by narrative,

memorabilia sale ever staged in auction history, a

provenance and emotional connection as much as

truly remarkable result considering that he had

by traditional notions of category or medium.

purchased many of the objects in his collection over the past decade.

These results reaffirm a broader shift within the market toward material that transcends

And this is not the end of the Jim Irsay Collection.

conventional definitions of “art” and instead

On 1 July 2026, Christie’s, New York will offer the

reflects shared cultural memory. Whether a draft

fifth and final sale of the series: Icons of History

of the Constitution, a guitar that reshaped modern

which will feature important historical documents,

music, or a manuscript that defined a generation,

letters and artifacts from the American Revolution

such objects resonate precisely because they

to the dawn of the twenty-first century. Rather than

embody moments that continue to define who

Gilmour, Clapton, Garcia, and Kerouac, it will be

we are. As Christie’s looks ahead to forthcoming

Washington, Lincoln, Roosevelt and Churchill (to

anniversaries and future landmark sales, the

name a few).

success of these auctions suggests a sustained and growing appetite for objects that tell meaningful

Although We the People: America at 250 and the

stories: bridging history and popular culture,

Jim Irsay Collection were two very different types

and reinforcing the enduring power of tangible

of auction, the former being a various owner sale

connections to the past.

12

Christie’s Bulletin for Professional Advisers

CAST AWAY, 2000: A HERO PROP "WILSON" VOLLEYBALL

13

Christie’s Bulletin for Professional Advisers

Worn Histories: Jewellery, Identity and Lasting Value Since Christie’s first jewellery auctions, the allure

performance against the backdrop of today’s

of royal, aristocratic and celebrity provenance has

increasingly uncertain macro political and economic

fascinated collectors and generated widespread

environment? And more broadly, do these results

interest in our sales. Jewellery has always been

point to a renewed and widening global appetite

prized for its talismanic and emotional power:

for jewellery at auction today?

wearable expressions of memory, sentiment, and

Henry Bailey Head of Jewellery Department, London Christie’s Henry Bailey is Head of the Jewellery Department at Christie’s London, where he oversees valuations, client advisory, and business development for the firm’s London jewellery sales, working in close collaboration with Christie’s international jewellery specialists. He joined Christie’s in 2020 following experience as a jewellery specialist at an international auction house based in London.

Henry is a Graduate Gemologist (G.G.) of the Gemological Institute of America and holds an M.A. from the University of Edinburgh.

identity, drawing in humanity for millennia. When a

The ingredients for a stellar jewellery auction

jewel appears at auction with a direct link to historic

remain much the same today as they have ever

events or distinguished owners, its emotional

been: exceptional jewels set with the highest

resonance for potential buyers is significantly

quality untreated gemstones; beautifully crafted

heightened, and in today’s market, the importance

and innovative mountings; iconic designs from the

of such provenance has never been greater.

great jewellery houses (Cartier, Van Cleef & Arpels and others) and, crucially, the spark that ignites any

In spring 2025, Christie’s Magnificent Jewels

auction: provenance.

auctions in both New York and Geneva achieved an unprecedented milestone, selling 100 per cent of

What has changed today is that these value drivers

the lots in each sale, a feat never before achieved

have been dramatically amplified by the maturing of

in one ‘various owner’ sale, let alone two within a

the internet and the rise of social media. Jewellery

month. In Geneva, all 115 lots realised a total of $72

auctions now reach an exponentially wider,

million, while in New York all 135 lots sold for $88

truly global audience, a shift accelerated by the

million. A combined $160 million realised within

pandemic, as collecting and transacting has become

weeks, with not a single jewel unsold.

increasingly online, particularly for signature jewels from the main jewellery houses. At the same time,

In the same year Christie’s November London

a vast and growing ecosystem of digital jewellery

Jewels sale became the highest-value online sale

content is being consumed by a new generation of

ever held at Christie’s London, and the most valuable

informed and engaged collectors: from specialist

London jewellery auction since 2016. In Paris, the

Instagram accounts dedicated to tiaras and royal

jewellery department surpassed, by some distance,

jewels to educational information about untreated

its previous annual sales record, set only the year

gemstones.

before. Meanwhile in Hong Kong, The Regent Kashmir sapphire ring sold for approximately $10

Only a few decades ago, jewellery sales were

million, setting a record for the highest price per

largely confined to members of the professional

carat ever paid for a sapphire at auction.

trade and a small circle of established collectors and connoisseurs. Today, the internet provides

Following these results, colleagues in the business

unprecedented international visibility and access

and observers beyond the auction world have

for buyers worldwide.

asked the same question: what is driving this

14

Worn Histories: Jewellery, Identity and Lasting Value

The Marie Therese Pink: A Historic Coloured Diamond Ring, mounted by JAR The 18th century diamond – likely from the prized Golconda region in India – was owned by Queen Marie Antoinette of France’s daughter and was mounted into a ring by the legendary Joel Arthur Rosenthal, known as JAR. Sold Christie’s New York, June 2025 for $14m, setting a record price at auction for a Fancy Purple-Pink diamond and for a jewel by JAR

15

Christie’s Bulletin for Professional Advisers

The Allure of Provenance Given the significant premium that provenance can confer on a jewel at auction, a key challenge in offering family jewellery with notable historical associations lies in presenting and realising the value of that provenance, while preserving

discretion

and

safeguarding

the

confidentiality of the current owner.

Each situation is different. In the case of The Wimborne Jewels and The Splendid Casket of Ancestral Jewellery sold in November 2025 it was possible to pinpoint the jewels to family members several generations removed from the current owners. A feat not always achievable.

Offered in London in November 2025, The Wimborne Jewels carried a compelling personal history, having belonged to the 1st Viscountess Wimborne (1880-1948), a renowned society beauty and one of Cecil Beaton’s earliest and most glamorous muses. In a rare and evocative insight, the family shared two remarkable portrait photographs by Beaton, showing Lady Wimborne adorned with several of the jewels presented for sale. The jewels themselves were of exceptional quality, most notably a magnificent Cartier Art Deco emerald bracelet that realised over £1 million. Yet it was the power of these images, bringing the jewels vividly to life and anchoring them to a moment of elegance and glamour, that ignited exceptional interest in the weeks leading up to, and throughout, the sale.

One of these images, The Shingled Vicereine, published in Tatler in 1928, presented Lady Wimborne as the embodiment of modern elegance.

Dressed in a striking Poiret gown, she wore her Art Deco ruby and diamond pendant suspended from a diamond chain, both of which featured in the sale. Completing the composition was her ruby and diamond coronet by Chaumet, a jewel with its own auction history, having been sold previously at Christie’s in Geneva in 1971. The second photograph offered a more intimate yet no less dramatic setting, showing Lady Wimborne in the ballroom An Art Deco ruby and diamond pendant sold from the Wimborne collection, shown suspended from a diamond chain.

16

of Wimborne House. Here she was adorned with

Christie’s Bulletin for Professional Advisers

A superb Cartier Emerald and Diamond Bracelet, sold at Christie's London from the Wimborne Collection, the group of 9 jewels sold for over £4m

her Art Deco emerald, pearl and diamond pendant,

glamour: qualities that cannot be manufactured,

emphasised the exceptional quality of the jewels

again worn from the same diamond chain, alongside

replicated or mass-produced. This continues to set

themselves, which were among the finest surviving

a magnificent Cartier emerald and diamond

truly important jewels apart.

examples of Victorian jewellery, incorporating

bracelet. Each of these jewels was included in the

gemstones of a size and calibre rarely encountered

auction, preserved not only as objects of beauty but

In a similar vein, The Splendid Casket of Ancestral

as tangible links to a vividly documented past.

Jewellery, offered for sale in Geneva last November,

outside royal collections.

was most closely associated with Helena Violet

The highlight of the group was a magnificent

In an era when collectors have instant access

Alice (née Fraser), 3rd Countess of Stradbroke

10.07-carat Burmese ruby and diamond Victorian

to global jewellery production at the click of a

(1874-1949), who was also photographed wearing

star brooch, worn by Lady Stradbroke alongside her

button, it is increasingly these rare combinations

several of the jewels offered for sale.

ruby tiara, also offered in the sale. The brooch went

of exceptional quality, provenance and visual

on to sell for almost $3 million and, while its value

narrative that command the greatest attention.

The images of Lady Stradbroke at the 1897

was overwhelmingly in the exceptional quality and

The

this

Devonshire House Ball and later at the coronation

size of the ruby, for connoisseurs the attachment

convergence perfectly, their allure extending

of King Edward VII in 1902 gave collectors a glimpse

of the provenance added a further layer of allure:

beyond

encompass

into the confidence, opulence and prosperity of

the knowledge the ruby had scarcely been seen in

association, atmosphere and a sense of lived

Britain at the turn of the last century. These images

public since the early 20th century.

Wimborne

Jewels

craftsmanship

exemplified

alone

to

17

Christie’s Bulletin for Professional Advisers

Coloured Gemstones: Rarity & Science The finest

level of scrutiny allowed prospective buyers to bid

coloured gemstones have long held a position

with complete confidence, secure in the knowledge

of prominence within our jewellery sales, led by

that the sapphire’s celebrated origin and untreated

the enduring appeal of sapphires, emeralds and

status remained unchanged, and underscored the

rubies. In recent years, however, this appetite has

importance now placed on transparency, precision

broadened to embrace other exceptional stones,

and trust at the highest level of the market.

including Paraíba tourmalines, spinels and fine topaz. This evolution reflects a noticeable surge

The Power of the Brands Another defining

in demand as collectors compete for gemstones

force shaping today’s jewellery market is the

of the highest calibre, increasingly aware of the

ever-increasing power of the great maison names,

growing rarity of truly fine examples and the finite

celebrated not only for their contemporary

nature of their supply.

collections but, perhaps more compellingly, for their historic and vintage creations. Houses such

In this environment, the role of rigorous

as Cartier, Van Cleef & Arpels and Bulgari have

laboratory certification has become indispensable.

been acutely attentive to the strength of their

Contemporary buyers, particularly at the upper

own heritage, actively preserving and promoting

end of the market, place paramount importance

their archival masterpieces and the illustrious

on recent reports that confirm a gemstone’s

clients who patronised them throughout the 20th

country of origin and attest to the absence of

century. This renewed focus has had a profound

treatment. Such documentation provides essential

effect on the secondary market, elevating

assurance and transparency, forming an integral

appetite for signed period jewels and sharpening

part of the buying decision. This represents a

collectors’ connoisseurship.

striking shift from earlier decades; jewellery sales in the 1970s and 1980s rarely included laboratory

Nowhere was this more evident than in the

reports, whereas today the majority of coloured

hugely popular Cartier exhibition at the Victoria

gemstones offered are accompanied by detailed

and Albert Museum. The exhibition was a vivid

scientific analysis. Together with rarity and beauty,

reminder

this confluence of quality, provenance and verified

evolution, charting the house’s innovations from

authenticity now defines the most sought-after

the early 20th century to the present day through

jewels at auction.

an exceptional assemblage of jewels. Visitors were

of

Cartier’s

extraordinary

creative

treated to an array of iconic pieces, many of which A telling example of this rigorous approach can

were familiar not only as museum-worthy objects,

be found in The Regent Kashmir Sapphire ring.

but as jewels that had, at various moments in their

Although the sapphire had appeared at auction

histories, passed through the auction rooms. The

twice within the preceding two decades, on each

exhibition succeeded in crystallising an important

occasion accompanied by laboratory reports

realisation for a wider audience: that jewels of true

identifying it as of Kashmir origin and unheated,

museum calibre are not confined to vitrines, but

a further step was taken ahead of the most recent

are periodically available on the open market. In

sale. In 2025, two fresh Swiss laboratory reports

turn, this has fostered a deeper public awareness

were commissioned from Gübelin and the SSEF,

and appreciation of historic signed jewels, and

ensuring absolute continuity with, and confirmation

has further strengthened demand for the finest

of, the earlier scientific findings. This additional

examples when they appear at auction.

18

Worn Histories: Jewellery, Identity and Lasting Value

A Late 19th Century Ruby and Diamond Star Pendant/Brooch and Tiara/Necklace from the collection of Helena Violet Alice, Countess of Stradbrooke (1874 - 1979), sold for $2.8m and over $700,000 respectively in November 2025.

19

Christie’s Bulletin for Professional Advisers

Conclusion While the fundamental ingredients of a great jewellery auction remain unchanged, exceptional quality, rarity, craftsmanship and provenance, these elements are being amplified more

powerfully

than

ever

before.

Digital

platforms, social media and online cataloguing have transformed how jewels are seen, understood and appreciated, creating a more informed and globally connected audience of collectors. Today’s buyers are not only acquiring remarkable objects, but engaging deeply with their history, context and cultural significance.

Across all segments of the market, from family jewels with compelling personal narratives, to the rarest untreated coloured gemstones, and the most iconic creations by the great jewellery houses, demand is increasingly focused on pieces that offer depth as well as beauty. Provenance has become a vital catalyst, laboratory science provides essential reassurance, and the renewed visibility of historic maison masterpieces, often reinforced by museum exhibitions,

continues

to

elevate

collectors’

expectations and ambitions.

There is no single explanation for the exceptional momentum currently seen in jewellery auctions.

However, the consensus among colleagues and industry professionals who have witnessed multiple is

market

experiencing

cycles a

is

clear:

defining

jewellery

moment. With

unprecedented global participation and sustained competition for the finest examples, jewellery auctions today occupy a position of renewed strength and relevance, firmly established as one of the most dynamic and compelling sectors of An Exceptional Cartier Art Deco Diamond Necklace, only a handful of Cartier diamond necklaces of this scale are recorded, with this necklace amongst the finest jewels created by the iconic Cartier London branch in the early 20th century.

Sold Christie’s Geneva, November 2024, for $5.5m

20

the global art and luxury market.

Christie’s Bulletin for Professional Advisers

The Regent Kashmir Sapphire Ring, weighing 35.09 carats. Sold Christie’s Hong Kong May 2025 for $9.5m, setting a record price at auction for a sapphire price per carat. The sapphire was previously sold in 2000 at auction for $850,000, reflecting the increased appreciation for the best coloured gemstones

21

Old Masters Evening Sale London | 30 June 2026

PROPERTY FROM A DISTINGUISHED PRIVATE COLLECTION

EXHIBITION 26 June – 30 June 2026 8 King Street London, SW1Y 6QT CONTACT Maja Markovic mmarkovic@christies.com +44 (0) 20 7389 2090

JAN VAN HUYSUM (AMSTERDAM 1682-1749) Fruit and flowers in a wicker basket and other fruit on a marble ledge, a column and terracotta urn with other flowers behind signed 'Jan Van Huÿsum fecit' (lower left) oil on panel 31⅜ x 23⅝ in. (79.7 x 60 cm.)

Estimate on request Other fees apply in addition to the hammer price.

See Section D of our Conditions of Sale at the back of the Auction Catalogue

christies.com

Old Masters Evening Sale London | 30 June 2026

PROPERTY FROM A DISTINGUISHED PRIVATE COLLECTION

EXHIBITION 26 June – 30 June 2026 8 King Street London, SW1Y 6QT CONTACT Maja Markovic mmarkovic@christies.com +44 (0) 20 7389 2090

JAN VAN HUYSUM (AMSTERDAM 1682-1749) Flowers in a terracotta vase and a bird’s nest on a marble ledge before a niche signed and dated 'Jan Van Húÿsú[m] / fecit 1734' (lower centre, the ‘m’ partly hidden by a rosebud) oil on panel 31⅞ x 23⅞ in. (81 x 60.6 cm.)

Estimate on request Other fees apply in addition to the hammer price.

See Section D of our Conditions of Sale at the back of the Auction Catalogue

christies.com

Christie’s Bulletin for Professional Advisers

Exporting Works of Art: Binding offers

In the Summer 2022 edition of this Bulletin, I

questions with the intention of capturing items

reported on the initial operation of the newly

falling into the widest net of national significance/

introduced binding offer process for the export

history, aesthetics and scholarship:

of works of art subject to a deferral of the export licence. At that stage, the process was very much

1. History (Waverley One): Is the object so closely

in its teething stage and, inevitably, unfamiliarity

connected with UK history and national life

with its operation was leading to increased delays

that its departure would be a misfortune?

in resolving export deferral cases. It is now five

(Includes items of major local importance or

years since the arrangements came into force and

significant collections).

it seems a suitable time to reflect on the process of binding offers and how they have been operating Ruth Cornett, CTA TEP Senior Director, Heritage and Taxation Advisory Service Christie's rcornett@christies.com +44 (0) 20 7389 2102 Prior to joining Christie’s, Ruth Cornett worked as a tax adviser in a number of professional firms in the City and the West End of London. After training as an art historian and working as a curator in the V&A, Ruth changed careers in 1992, studying law and qualifying as a Chartered Tax Adviser (CTA) in 1998. Ruth has advised a broad spectrum of clients on a range of tax matters with a particular emphasis on capital gains tax, inheritance tax and income tax. To consolidate her expertise in these areas, Ruth qualified as a Trust and Estate Practitioner (TEP) in 2008. Ruth lectures frequently for Christie’s Education and STEP on tax and heritage matters, has contributed to leading publications in this field and sits as an observer on the Tax and Political Committee of Historic Houses (HH).

since 2022.

2. Aesthetics (Waverley Two): Is the object of outstanding aesthetic importance?

3. Scholarship (Waverley Three): Is the object of outstanding significance for the study of some

It is, perhaps, useful to give readers a précis of the

particular branch of art, learning, or history?

export licensing process as it currently operates.

The process is designed to be fair to all parties but

An object need only satisfy one of the Waverley

can be tricky to navigate for many practitioners,

criteria, in the opinion of the expert adviser, for the

as the rules and procedures are not encountered

adviser to raise an objection, but in addition to the

frequently in professional practice. All works of art

quality threshold, an object must also have been in

above certain value thresholds must have a licence

the UK for at least 50 years. With the combination

for export from the UK. The value thresholds

of the high quality threshold and the 50-year rule,

depend on the applicable category for the object

the overwhelming proportion of applications for

which, for certain classes, may be as low as zero.

export are not subject to an objection, for example,

A licence to export an object (a work of art or a

in the year to 30 April 2025, there were 28,307

cultural object) may be sought for a temporary

applications referred to the relevant expert advisers

period, in which case the object must return to

and only 20 cases were referred for consideration

the UK before the designated period ends, or for

by the independent committee.

permanent export. Applications for permanent export are referred initially to the expert adviser for

Once an objection has been raised, the case is

the category, usually a senior curator at a national

referred to the Reviewing Committee on the Export

museum or recognised expert in the field, who is

of Works of Art and Cultural Property (RCEWA).

asked to consider the application and report to the

The RCEWA considers the application in light of the

Export Licensing Unit of the Arts Council.

expert adviser’s objection and against the Waverley criteria, to decide whether the object is a national

Historically, the UK has aimed to balance the

treasure. If the RCEWA does find that the object

need of the art market for the free-flowing,

is a national treasure, it makes a recommendation

international circulation of works of art, with the

to the Secretary of State to defer the issue of the

wish to retain important heritage objects, known

export licence. If the RCEWA recommends that the

as national treasures, in the UK. The process

export should be deferred, it is highly likely that the

allows the expert adviser to raise an objection to

Secretary of State will follow that recommendation.

an export application where that adviser considers

24

the object may meet at least one of criteria to be

The purpose of deferral is to allow time for an

a national treasure and its export from the UK

institution in the UK or a private buyer who is

would be a misfortune. Collectively, the criteria

willing to keep the national treasure in the UK, to

on which an objection may be raised are known

come forward and match the value declared on the

as the “Waverley criteria”, so named after the first

export licence. In these circumstances the hope is

chairman of the committee which considered the

that a national treasure will be kept in the UK, but

export rules, and they are designed as a series of

also to ensure that the owner will be compensated

Exporting Works of Art: Binding offers

GUIDO DI PIERO, FRA GIOVANNI DA FIESOLE, POSTHUMOUSLY KNOWN AS FRA ANGELICO (NEAR VICCHIO, C. 1395⁄1400-1455, ROME) The Crucifixion with the Virgin, Saint John the Baptist and the Magdalen.

Saved for the nation in 2024 and acquired by the Ashmolean Museum, Oxford.

25

Christie’s Bulletin for Professional Advisers

DAME BARBARA HEPWORTH (1903-1975) Sculpture with Colour (Oval Form) Pale Blue and Red signed, inscribed and dated 'Barbara Hepworth/"Sculpture with colour/ pale blue & red"/1943' (on the underside of the base) painted wood and string, unique 19¾ in. (50.2 cm.) long Carved in 1943.

Saved for the nation in 2025 and acquired by The Hepworth Wakefield.

26

Christie’s Bulletin for Professional Advisers

for its value. The RCEWA also recommends

many owners find unappealing. If the owner does

appoint advisers to work with interested parties

the duration of the deferral period and, if no

decide to withdraw, it is the national treasure

(institutions or private buyers) to draw up a

institution or private buyer comes forward to try

which is banned from export, even if it is sold

simple sale and purchase agreement to ensure

to match the value during that time, the export

while the ban applies. An owner may make a fresh

that these points are covered after the call option

licence will be granted.

application for export at the end of the ban, but

has been exercised.

there is no guarantee that a licence will be issued, The deferral period for a national treasure is split

and it will mean a second hearing to consider the

The Arts Council and the Export Licensing Unit

into two parts, and the binding offer process arises

fresh application. Consequently, many owners

have recognised the practical difficulties and earlier

between them. The first deferral period allows time

prefer to follow the binding offer process as the

this year, I took part in an online seminar which

for interested parties to decide whether to try to

outcomes are either they are compensated for

was designed to address some of the points where

raise the funds to keep the national treasure in the

the value of the national treasure, or the export

problems have arisen. The key takeaways were:

UK and to make initial approaches to supporters

licence is granted. The binding offer process is

and funding bodies. The second deferral period

therefore pursued increasingly frequently.

•

The need for open communication and dialogue between the parties involved

is when most significant fund-raising takes place.

Notice of the intention to try to match the value

The template for the binding offer process is set

must be given to the Export Licensing Unit by the

out in The Procedures for Exporters (latest edition

end of the first deferral period, at which point the

2024) which also includes the option template,

advisers familiar with the workings of the

binding offer process commences.

and which may only be varied slightly. From

RCEWA

•

Obtaining good advice at the outset with

experience we have found that parties interested •

Recognition by institutions/private buyers that

The binding offer maybe described as an

in acquiring national treasures have found the

irrevocable call option, granted to a party which has

template to be helpful in giving certainty over the

made a serious expression of interest in acquiring

wording but that the process of implementation

the national treasure and exercisable no later than

is difficult. The template requires a condition

by the end of the second deferral period, in essence

report before the call option is granted and a

and potentially lose their new acquisition, and

it is the right of first refusal to buy the national

second condition report immediately before

that this disappointment is compounded

treasure. By introducing the option arrangements,

exercising that option. Clearly this is designed to

where delays arise. In a period of higher

the government’s aim was to ensure that institutions

ensure that owners continue to take appropriate

interest rates, for owners to have neither their

that had undertaken significant fundraising to keep

care of the national treasure until the outcome

work of art where they would like it, nor their

a national treasure in the UK, were not thwarted by

of the export process is known but can cause

purchase price refunded quickly leads to

the owner withdrawing from the process at the last

some owners to chafe at the inevitable delays

increased frustration.

minute. While the ambitions are understandable,

caused by obtaining condition reports. Some

the process has been slow, and many institutions

owners may resent any suggestion that they will

have struggled to understand the process while at

not be fully compensated if the national treasure

such as the condition reports, delivery and

the same time submitting funding applications.

has deteriorated whilst in their care. The second

confirmation of safe receipt is essential.

condition report is prepared by the Buyer, after

We have found that these matters can be

Immediately after the end of the first deferral

exercising the Option, but before completion of

inadvertently overlooked when so much effort

period, the Arts Council will advise an owner

the sale. If the second condition report shows

has been directed towards fund-raising.

if a serious expression of interest to acquire

that the object has sustained damage since

the object has been made. The owner then

the first condition report was prepared, then a

The binding offer process is likely to remain an area

has fifteen business days in which to consider

reduction will be made to the purchase price the

of uncertainty for many practitioners, but the efforts

whether to accept the offer and to proceed with

amount of such reduction to be determined by

made to publicise and educate participants about

the grant of a binding option. An owner is not

an independent third party agreed by the Buyer

the details of the procedures are welcome. We can

obliged to grant a binding option. At the end of

and Seller. The binding option agreement is also

only hope that when further reviews of the scheme

the first deferral period the owner could decide

silent on the ultimate mechanics of delivery,

take place, the teething problems and delays will no

to withdraw the export application but in doing

payment arrangements for the matching funds

longer be causes for concern. In the meantime, early

so the owner will trigger an export ban on the

and the transfer of title after the option has

engagement with specialists is essential for both

national treasure for around ten years, which

been exercised. As a result, owners have to

exporters and would-be purchasers.

speed is of the essence •

•

Owners will be disappointed to have a deferral

That engagement with practical aspects

27

Christie’s Bulletin for Professional Advisers

Christie’s Education: Untangling the Complexity of the Art Market for a Global Audience

It will come as no surprise to readers of the Bulletin

What a professional development programme like

for Professional Advisers that art appears in many

the recent Family Offices course illustrates is that

complex conversations beyond the saleroom.

bridging this threshold is a matter of knowing which

Increasingly, those conversations are being held in

questions to ask, in what order, and to whom.

family offices: organisations established to manage the wealth, investments and long-term interests of

A tax advisor who understands that the art market

one or more families.

values works differently from other asset classes will ask better questions of a valuer. An estate planner

Ted Sandling Global Director of Education Christie's Ted leads Christie’s Education. After joining Christie’s in 2008, he went on to head UK marketing strategy, before leaving to pursue interests in digital technology and cultural history, working with early-stage startups and writing the Evening Standard bestselling book London in Fragments. He rejoined Christie’s in 2016 to launch filmed online courses, before taking on his present role.

On 1 May of this year, Christie’s Education

who grasps the distinction between an artist’s

welcomed a group of principals and advisers to our

primary and secondary markets will structure

King Street saleroom for The Art Market for Family

conversations with clients more precisely. A wealth

Offices, a one-day programme designed to address

manager who knows when art-backed lending is a

an increasingly pressing question in contemporary

realistic option, and when it is not, can engage with

wealth management: what do professional advisers

that conversation rather than defer it entirely. None

need to know about art?

of this requires deep art-historical knowledge. It requires a working understanding of the market’s

The conversations that took place during the day

logic, language and conventions.

reflected the sophistication of the audience and the breadth of what art now asks of those responsible

As Christie’s Education has evolved, we have come

for advising around it. Works of art sit at the

to understand that different audiences require

intersection of several disciplines at once. They

different points of access to the art world. The

may be cultural objects, financial assets, heirlooms,

needs of a collector are not identical to those of

philanthropic instruments, legal liabilities and,

a professional advisor, an institutional partner, a

most of all, intensely personal expressions of

student or an emerging art-world professional.

taste. Professionals are increasingly being asked to

Each audience requires a different level of detail, a

understand how those coexist, and how they can

different pace and sometimes a different framing of

affect decisions made around a collection.

an issue. Our role is to shape Christie’s underlying expertise into forms that are useful and usable for

A collection assembled over a lifetime as an

those audiences.

expression of passion may become, in the context of an estate or succession, an asset with

This is why format matters. The choice between

its own demands. The question for advisers is

an online or livestreamed course, an in-person

not simply “what is it worth?”, but what kind of

programme

object it is, how value is established, what risks

determines how people learn and the kind of access

may sit behind it, who should be consulted,

they receive. Increasingly, format is part of the

and when. Collections might be held in family

educational design.

or

a

bespoke

training

session

trusts, investment portfolios and philanthropic foundations. They are subject to tax legislation in

Pre-recorded online courses provide international

multiple jurisdictions and raise questions that are

reach and a clear structure, available at the learner’s

legal, financial, reputational and personal.

own pace. Each course combines filmed lectures with shorter documentary-style material featuring

28

Professional advisers are not expected to become

leading figures in their fields. In our economics and

art specialists, but there is a real and practical

law courses, that may include market professionals,

threshold of fluency below which the risk of

lawyers and other practitioners. In our luxury

misreading a situation, or not recognising that

courses, curators, founders and makers, such as the

specialist input is needed, becomes significant.

watchmaker Richard Mille or the director of the

Christie’s Bulletin for Professional Advisers

29

Christie’s Bulletin for Professional Advisers

Cartier Collection. Filming an online course allows

Less

visibly,

Christie’s

also

travel. For those unable to travel, students can

Christie’s Education to turn a limited encounter

increasingly

with a high-profile contributor into lasting access

programmes

access Christie’s programming from around the

calibrated to a particular sector, institution

to their insights for an international student body.

or professional need. Bespoke programming

world digitally, while the Family Offices course showed another version of what this looks

allows us to shape content around the precise

like: a specialist audience travelling to London

Livestreamed courses offer something different.

questions a group needs to answer. That might

from around the world, with attendees from

They give students access to structured teaching

mean collections management training for

Singapore and Sydney, Luxembourg and Lima.

with the immediacy of live discussion. The

the museum sector, art-centred client service

production values are necessarily different from

training for a financial institution, or a behind-

That is increasingly the role of Christie’s

those of a filmed course, but what attendees gain

the-scenes

Christie’s for a

Education: to make the knowledge of the art

is responsiveness. Students can ask questions,

corporate audience. In each case, the value lies

market available in forms that meet people

specialists can adapt to the interests of the group,

not only in access to expertise, but in having that

where they are and help get them where they

and the course can respond more directly to

expertise arranged around a specific audience

need to be. For professional advisers, that may

changes in the market or to a particular moment in

and purpose.

mean developing enough fluency to recognise

asked

to

experience

Education design

at

is

the auction calendar. They can also increase access:

the right questions. For collectors, it may mean

we try to offer regular free livestreamed sessions

London remains one of the great centres of

understanding a category or market with greater

offering dives into market moments.

the international art market. For Christie’s

confidence. For institutions, it may mean building

Education, it provides an intellectual centre of

specialist capability. For international learners, it

In-person programming offers proximity, depth

gravity as well as a physical base. As an active

may mean access to Christie’s expertise without

and, often, direct encounters with works of art.

market institution, Christie’s brings together

needing to be in London.

At King Street, education takes place inside the

expertise in art, luxury, collecting, valuation,

auction house: near the saleroom, near specialists,

provenance, law, logistics and sale strategy. The

Education does not replace specialist advice,

near exhibitions and, at the right moments, near

knowledge that informs Christie’s Education

and it certainly can’t simplify the complexity

the objects themselves. This proximity changes

programmes comes from the same environment

of the art market. But we see its value in

the conversation. A discussion about valuation,

as the knowledge that shapes sale decisions,

making that complexity more navigable. By

condition, provenance or collecting strategy

advisory relationships and our role in the

combining the authority of Christie’s expertise

becomes more tangible when grounded in the

global art market. The specialists who teach for

with formats designed for different audiences

experience of looking closely at objects. Christie’s

Christie’s Education are not describing the art

and geographies, Christie’s Education extends

Education was founded as a centre for object-

world from outside it, allowing our programmes

the knowledge of the saleroom into the wider

based learning.

to draw on the energy of a live market institution

professional world. The first Family Offices

rather than commenting on that market from a

programme was an example of that in practice,

Convening in-person also creates the conditions for

distance. Speakers share knowledge formed

but it also points towards a broader future: one

relationships to develop. As we saw during The Art

through direct professional experience.

in which connections within the art market and a

Market for Family Offices, in-person programming

wider understanding of its implications become

allows participants to build connections with a cohort

At the same time, our multi-channel model

part of how advisers, collectors and institutions

of peers working across adjacent professions, as

means this expertise no longer has to remain

engage with art responsibly, intelligently and

well as with Christie’s Specialists. Several attendees

local. Online, livestreamed, in-person

with confidence.

noted that conversations over coffee breaks were as

bespoke programmes allow knowledge to

useful as the formal sessions themselves.

30

and

Christie’s Bulletin for Professional Advisers

31

Christie’s Bulletin for Professional Advisers

Matters of the Art: a solicitor’s perspective on estate planning

This article is intended for individuals who have

Brussels IV

purchased or inherited the sorts of items in

In most EU member states (not Denmark, not

which this historic auction house, Christie’s, deals.

Some of you will be British, some of you will be exclusively international. Hopefully you will find something of interest in what follows.

Chattels

Ireland and, for the avoidance of doubt, not the UK) the EU Succession Regulation (EU No. 650/2012), commonly known as Brussels IV, applies. The default rule in those EU countries is that the law of wherever the deceased was habitually resident at death governs the succession

In England we use an old French word to

of whole estate, including all chattels wherever they

describe moveable personal property. From my

may be physically located in the EU.

perspective the fact that a significant proportion Arthur Byng Nelson Partner Sherrards

of my clients’ wealth could consist of such

Article 22 allows an individual to override that

moveable high value items gives me immediate

default by electing for the law of their nationality.

Arthur Byng Nelson is a Partner in Sherrards’ Private Wealth Team and is Head of Art & Heritage. He advises individuals and families on succession planning, wills, trusts and the establishment of charities.

pause for thought: how moveable exactly are the

An EU national who is foreign domiciled and

items in question, what are the past and present

habitually resident in England can therefore elect

values of each, what will be the Inheritance

for Italian or French law to govern how their EU-

Tax treatment of the client, which laws will

situated chattels pass on death. A British national

govern the chattels, how divisible is the item (or

living in Paris can elect for English law instead

collection). And are the children interested?

and since English law has no forced heirship that election can, in principle, allow them to leave

Lex situs

their collection to whomsoever they choose. But

We English are not alone in using Latin to

beware! Such an election is not always effective

describe legal principles. This means, broadly, that the law that applies to the property will be the law of the place where the property is located. Therefore it is essential for any advisor to understand the exact location of the items in question.

and France, as an illustration, has amended its Civil Code specifically to limit the reach of Article 22. I strongly recommend seeking advice from lawyers in the relevant jurisdictions before action (or inaction).

In summary, Brussels IV affects how chattels may pass but does not affect an individual’s Inheritance Tax position.

Opposite: A HIGHLY IMPORTANT QUEEN ANNE SILVER-MOUNTED EBONY STRIKING TABLE CLOCK OF SMALL SIZE THOMAS TOMPION AND EDWARD BANGER, LONDON, CIRCA 1708, NO. 460 Accepted in lieu of Inheritance Tax and allocated to the Science Museum in 2019

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Christie’s Bulletin for Professional Advisers

Inheritance Tax (IHT)

But note that in the United Kingdom an asset

Not at all straightforward therefore in the context

England, Wales, Scotland and Northern Ireland

transferred on death benefits from an automatic

of death. My recommendations in the context of

uplift in base cost meaning any accrued capital

estate planning are as follows:

all share the same IHT regime. Until recently “domicile” of the individual in question was the defining factor: a concept rooted in private international law, resistant to precise definition

gain is extinguished entirely, with the personal representatives and subsequently the beneficiary

1. Create a Digital Asset Inventory

acquiring the asset at its market value as at the date of death, wiping the CGT slate clean. A very

The owner should maintain a clear written record

useful planning tool.

of all digital asset holdings, including:

based test applies to an assessment of the liability

Digital Assets

•

The type and description of each NFT

of an individual to UK IHT: if an individual has

Christie’s holds the record for the most expensive

been UK tax resident for 10 or more of the

digital artwork ever sold to a single owner

•

The platform or blockchain on which it is held

preceding 20 tax years they become a “long-term

EVERYDAYS: THE FIRST 5000 DAYS by Beeple,

•

Whether it is held in a self-custody wallet or

UK resident”. An individual who is a long-term UK

sold for $69,346,250 in March 2021. Historically

resident is liable to IHT on their worldwide assets.

personal property fell into one of two categories:

What this means, of course, is that there are a

either “things in possession”, chattels, or “things in

number of tax planning opportunities available

action” such as debts or contractual claims. Digital

for individuals who have not yet been resident in

assets fell into neither category.

and frequently the subject of costly dispute between taxpayers and His Majesty’s Revenue & Customs. Since 6 April 2025 a new residence-

the UK for ten years.

As a result the Property (Digital Assets etc) Act Capital Gains Tax (CGT)

2025 was brought into legislation, coming into

The concept of a state taxing an individual’s gains

force on 2 December 2025, thereby recognising a

is not unusual. However there are two elements of our system here that often puzzle international clients: first the fact that the tax is triggered not only by a sale but also by a gift. Secondly the individual responsible for paying the tax is the

third category of personal property: assets existing only in electronic form such as cryptocurrencies and non-fungible tokens (NFTs).

Ownership is proved entirely by control of a

transferor, not the transferee.

digital wallet and that wallet is secured by two

A Wasting Asset

alphanumeric string) and a seed phrase (typically

Under Capital Gains Tax legislation if an item has “a predictable life not exceeding 50 years” then it will be entirely exempt from CGT. Cars (classic, super etc.) fall squarely within this definition as they have mechanical components that deteriorate and wear, giving them a finite useful life. So too do “antique clocks and watches, such as `Tompion’ clocks”, I quote from HMRC’s own guidance. Unfortunately other chattels such as paintings, sculpture and furniture all remain subject to CGT as they are deemed to have a much longer life than 50 years.

critical pieces of information: a private key (a long 12 to 24 words generated when the wallet is first created, which can be used to recover the wallet if the private key is lost). To transfer an NFT to another person, whether as a gift, a sale or a transfer to an executor, the current owner must use their private key to digitally “sign” and authorise the transaction on the blockchain.

Once that transaction is confirmed on the network, ownership passes irrevocably and instantaneously to the recipient’s wallet address. There is no central

via a custodial platform •

An approximate current value

2. Record Wallet Details and Access Information Securely (never within the body of a will) 3. Consider a

Hardware

(Cold) Wallet

for

Significant Holdings 4. Consider Appointing a Technically Literate Executor 5. Be aware that Ownership Might Not Include Copyright A point which frequently surprises clients: purchasing an NFT gives ownership of the token on the blockchain but does not automatically transfer the underlying intellectual property rights in the associated work. The copyright in the digital image or artwork typically remains with the creator unless explicitly assigned. This distinction has implications both for the value attributed to the NFT in the estate and for what beneficiaries can actually do with the asset after they receive it.

Discretionary trusts in Wills

registry, no intermediary and no mechanism for

A discretionary trust in a will is a beautiful thing,

recovery if the private key or seed phrase is lost.

and can be of particular interest to owners of special chattels. Such a trust comes into existence on the death of the testator and offers a number of advantages to a will without one. These include:

34

Christie’s Bulletin for Professional Advisers

EVERYDAYS: THE FIRST 5000 DAYS by Beeple, sold for $69,346,250 in March 2021

35

Christie’s Bulletin for Professional Advisers

Charitable opportunities A direct bequest of an object to a national museum or a registered charity attracts an outright exemption from IHT and CGT, meaning the full value of the object passes to the institution with no tax charge. However, in order not to create surprises on either side, I strongly recommend that clients take a much more proactive approach in lifetime, building a relationship with the intended institution and, perhaps, lending the item. Then if all goes well the loan may be turned into an outright gift on death.

Conditional Exemption, The Cultural Gifts Scheme, Acceptance in Lieu Three schemes exist which are intended to ease the tax position for owners of “pre-eminent” items.

The three schemes are not mutually exclusive and can be used in combination: deferring a charge during the testator’s lifetime, reducing it on an inter vivos disposition or extinguishing it entirely through a transfer to a public collection in satisfaction of an outstanding liability.

Finally At the outset I posed the question: are the children interested? It is, in truth, the question that underlies everything else discussed in this article. The most technically accomplished estate A Queen Anne toilet service, London, 1702, maker’s mark of Benjamin Pyne (circa 1653–1732). Accepted in lieu of Inheritance Tax in 2024.

plan can still fail the client if it puts the family in a position it does not want.

My strong recommendation is therefore that before any document is drafted the owner

1. Confidentiality

2. Flexibility for unknown future circumstances

The identity of the assets passing from the

The trustees, guided by the letter of wishes, will be

deceased into the trust can remain confidential

able to take action (even ending the trust) if it is

from public eyes. The will simply settles “all my

right in light of all the circumstances at death, such

personal chattels” into the trust and the named

as the family situation or tax law changes.

potential beneficiaries may be as broad as “my descendants and their spouses”. In this way who

3. Time

actually benefits and by how much never appears

The trustees will have two years to exercise their

in any public document. The detail of who is to receive what is set out by the testator in a separate, confidential, letter of wishes.

36

discretion without any negative tax consequences.

should sit down with their family and have the conversation. Thereby establishing, clearly and honestly, what each significant item means to each person who might one day receive it. That conversation, uncomfortable as it sometimes is, is the foundation upon which every other planning decision should be built.

The law provides the tools. The family provides the instruction. A solicitor’s role, at its best, is to hold both of those things together.

RUTH CORNETT, CTA TEP Senior Director, Heritage & Taxation Advisory Service rcornett@christies.com +44 (0) 20 7389 2102

LUISA ROMANELLI, CTA Associate Director, Heritage & Taxation Advisory Service lromanelli@christies.com +44 (0) 20 7389 2725

ZITA GIBSON Senior Director, Head of Business Development, EMEA zgibson@christies.com +44 (0) 20 7389 2488

TOM LEGH, TEP Senior Director, Estates, Appraisals & Valuations tlegh@christies.com +44 (0) 20 7389 2164

GEORGIE MAWBY, TEP Director, Estates, Appraisals & Valuations gmawby@christies.com +44 (0) 20 7389 2804

MARGA F-A CHICLANA Senior Coordinator, Heritage & Taxation Advisory Service mfachiclana@christies.com +44 738 549 1548

Heritage & Taxation Advisory Service MAX PECHSTEIN (1881–1955) Stilleben mit Figuren und Blumentopf [Still life with figures and vase of flowers], 1918 oil on canvas 39⅜ x 29½ in (100 x 75 cm) Accepted by HM Government in lieu of Inheritance Tax from the collection of Professor C M Kauffmann and Dorothy Kauffmann and temporarily allocated to the Ashmolean Museum, University of Oxford, pending a decision on the permanent allocation.

Ruth Cornett rcornett@christies.com +44 (0) 20 7389 2102 Negotiated sales • Heritage exemptions • Cultural gifts scheme Pre- and post-sale tax advice • Other tax valuations

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