Non-resident individuals

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STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

Finance Act 2025 (FA 2025) which received Royal Assent on 20 March 2025, implements legislation to abolish the remittance basis of taxation and replace it with a residence-based regime, commencing on 6 April 2025. FA 2025 also replaces domicile as the key factor in establishing liability to inheritance tax. Other changes include amendment of the rules determining excluded property status, the abolition of protected settlements status of offshore trusts, and changes to overseas workday relief.

For information on these changes, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26. See also: Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.

The main UK taxes which may apply to non-UK resident individuals are income tax, capital gains tax (CGT), inheritance tax (IHT), value added tax (VAT), national insurance contributions (NICs), the annual tax on enveloped dwellings (ATED) and stamp duty land tax (SDLT). Broadly, UK tax legislation is subject to territorial limits, so that

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Question of the week: W died on 06 April 2025. She was resident in England & Wales at her death and all her assets were situate in England & Wales. In 2018 (ie within seven years of her death) W and her husband H made joint lifetime gifts totalling £600,000 to their three children. At the time of the gifts, they were arguable domiciled in Gibraltar, and the gifts were made from Gibraltar-based assets. H died in 2021 domiciled in Gibraltar. Do the lifetime gifts have to now be brought into account for IHT in W's estate in relation to both her NRB and the transferable NRB from H's estate?

This Q&A considers the implications for inheritance tax (IHT) when a resident passes away. Specifically, it examines the scenario where lifetime gifts were made within seven years of death, and the deceased and their spouse were domiciled in a different jurisdiction at the time of the gifts. It also addresses how these gifts impact the deceased's estate, including the transferable nil rate band (NRB) from the spouse's estate.

Legislation Day: Draft Finance Bill 2026—Private Client analysis

Private Client analysis: On Legislation Day, 21 July 2025, the government published draft provisions to be included in Finance Bill 2026 (FB 2026, also known as Finance Bill 2025–26) together with accompanying explanatory notes and other supporting documents. The government also published consultation responses and made other announcements of interest to Private Client practitioners. This analysis provides an overview of the key Private Client tax provisions together with initial reactions from the market.

HMRC confirms new IHT rules on unused pension funds to apply from 6 April 2027

Law360: The government has confirmed that it is pushing ahead with its plans to apply inheritance tax (IHT) to wealth transferred through pensions in a move that experts say marks a ‘seismic’ change for the sector.

Legislation Day: Draft Finance Bill 2026—Tax analysis

Tax analysis: On Legislation Day, 21 July 2025, the government published draft provisions for inclusion in Finance Bill 2026 (FB 2026, also known as Finance Bill 2025–26) together with accompanying explanatory notes and other supporting documents. This analysis brings together the key business tax measures. Expert commentary has been provided by the LexisNexis Tax Consulting Editorial Board and Andersen, Blick Rothenberg, CMS, Eversheds Sutherland, Herbert Smith Freehills Kramer, Macfarlanes and Pinsent Masons.

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