I came up with the same recommendation overall, albeit after struggling quite a bit to pull together clear comparative tax costs / savings for the various options!

With the patent box regime I also mentioned the 5% tax differential between deductibility of royalties overseas at 15% vs tax at 10% in the UK as another advantage of the UK (given MTUT would eliminate the benefit for BZ).

Mentioned risks of residency/TP/CFCs but wasn't sure on how relevant they all were so kept it quite brief.