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. This Practice Note is an overview of the issues facing non-UK domiciliaries when purchasing a home in the UK with a mortgage. The use of debt to fund home ownership has been a common planning device for two main reasons: • the ability to reduce the inheritance tax (IHT) value of the home, and • to convert

Replacement of remittance basis with FIG and TRF regimes On 6 April 2025, the remittance basis system of taxation, which was available to individuals who were not domiciled in any part of the UK, was replaced by a regime based on residence. As a result, income and gains attributed to a beneficiary will be taxable on them by default without benefit of the remittance basis. However, new residents of the UK may be able to claim relief from UK tax on their foreign income and gains (FIG) for the first four years of residence, provided that they meet certain criteria. See Practice Note: Foreign income and gains regime from 6 April 2025. At the same time, a transitional regime, known as the temporary repatriation facility (TRF) was introduced and has the aim of encouraging former users of the remittance basis to bring their FIG which had arisen before 6 April 2025, to the UK. See Practice Note: Temporary repatriation facility—FAQs. Register of overseas entities A non-UK company that

Who is an ‘offshore client’? This Practice Note deals with common ownership structures of UK residential property for offshore clients who wish to use the property as a UK home. ‘Offshore clients’ meaning individuals who: • up to 5 April 2025, are non-UK domiciled and not deemed UK domiciled for UK tax purposes; and • from 6 April 2025, are not long-term UK resident for inheritance tax (IHT) purposes—see Practice Notes: A new residence-based regime for IHT from 2025–26 and New IHT regime from 6 April 2025—FAQs. This Practice Note does not deal with ownership of UK residential property for other purposes (eg investment). For guidance on property ownership for investment and other purposes, see the UK real property overview. Inheritance tax (IHT) IHT has always been a concern for offshore clients owning UK property. Property situated in the UK is within the scope of IHT, even if owned by an offshore client. Historically, UK property held within a non-UK company by an offshore client

This table compares the main taxes applicable in home ownership structures for UK residential property where the property is to be used as a UK home. It should be read with UK home ownership structures for offshore clients—outline. ‘Overseas clients’ meaning individuals who are not UK resident and; • before 6 April 2025, were non-UK domiciled and non-UK deemed domiciled, and • from 6 April 2025, are not long-term UK resident for inheritance tax purposes (see Practice Note: A new residence-based regime for IHT from 2025–26) Inheritance Tax (IHT) Capital Gains Tax (CGT) and corporation tax (CT) Annual Tax on Enveloped Dwellings (ATED) Stamp Duty Land Tax (SDLT) Part of gain arising

This Practice Note sets out the tax position of individuals who hold a UK residential property which they use as a home through an offshore company. This Practice Note does not deal with ownership of UK residential property through an offshore company for any other purpose (eg investment or development). For guidance on these aspects, see Practice Note: Property holding structures—direct tax and stamp taxes treatment of a non-UK company and the further reading link to Clarke's Offshore Tax Planning (Trusts and Companies)—Commercial and Investment property. For an outline of common ownership structures prior to 6 April 2025 for individuals who were neither domiciled nor deemed domiciled in the UK and who wished to use the property as a UK home, see Practice Note: UK home ownership structures for offshore clients—outline. In this Practice Note ‘offshore company’ means a company incorporated outside the UK which is not resident in the UK for UK tax purposes and whose shares are not registered in the UK. See Practice Notes: When a company is UK tax

Law360: UK home insurers continued to lose money in 2023, despite a slight improvement from the previous year, according to a report by Ernst & Young LLP.

The Prime Minister and Home Secretary hosted the first Organised Immigration Crime (OIC) Summit on 31 March 2025, bringing together over 40 countries to coordinate anti-people smuggling efforts. The government announced £30m in funding for Border Security Command operations and £3m for Crown Prosecution Service to expand international prosecution capacity. New bilateral agreements include France establishing specialist mobile units, Germany strengthening anti-smuggling laws, and Italy creating a joint taskforce on financial flows. The summit also engaged major social media platforms to address online promotion of irregular migration.

UK implementation of MiFID II and MiFIR The recast Markets in Financial Instruments Directive (Directive 2014/65/EU) (MiFID II) and new Markets in Financial Instruments (Regulation (EU) 600/2014) (MiFIR) were published in the Official Journal of the European Union (EU) on 12 June 2014 and came into effect on 3 January 2018. MiFID II and MiFIR significantly amend and expand the regulatory framework that was established by the Markets in Financial Instruments Directive (2004/39/EC) (MiFID). EU Member States were required to transpose the provisions of MiFID II into national law by 3 July 2017, while MiFIR has direct effect in Member States without transposition. MiFID II and MiFIR have been implemented in the UK through amendments to legislation drafted by HM Treasury, as well as Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) rules and guidance. The Financial Ombudsman Service (FOS) has also amended its standard terms and scheme rules affecting businesses subject to its voluntary jurisdiction. This Practice Note tracks the status of the implementation of MiFID II and MiFIR in the UK. For

UK in a Changing Europe researchers have examined the rise of fraudulent immigration advisors following a BBC investigation in April 2026. The investigation uncovered unregulated firms charging up to £7,000 for false asylum advice and alleged fraudulent advice was arising from some community organisations.

UK in a Changing Europe has published a blog post by Professor Catherine Barnard and Denzil Davidson examining why negotiations on a UK-EU youth mobility or ‘youth experience’ scheme are so complex. The authors explain that, although there is broad support for limited-time opportunities for young people to travel, study and work, the Trade and Cooperation Agreement (TCA) makes only limited provision for mobility. The blog notes that individuals moving between the UK and the EU for work or study must currently rely on national law, prompting calls for a youth mobility scheme for the 18–30s as part of a UK-EU reset. However, EU law limits the European Commission’s competence to negotiate a youth mobility scheme that includes work, as Article 79(5) of the Treaty on the Functioning of the EU (TFEU) reserves such decisions to member states.

The government has published its ten‐year Industrial Strategy, which is intended to drive investment and growth in the UK. It aims to support eight high‐growth sectors, develop productive public–private partnerships, and increase economic resilience and innovation while also addressing regional disparities. The strategy is underpinned by targeted public investment, regulatory reform, and long‐term support measures that stretch across infrastructure, skills, international trade and a wide range of supplementary policy areas. The document incorporates a number of immigration‐related plans in order to complement growth and talent needs. Many of these proposals were previously announced in the Immigration White Paper, but some more details are now included on timing and other aspects.

MLex: The UK working group on faster trade settlement outlined its recommendations on how the move to T+1 should take place, in a submission to the industry and regulators. The Accelerated Settlement Taskforce, chaired by industry veteran Andrew Douglas, said in its 75-page report that two things are needed for the move to T+1 to be successful— better automation, and a post-trade code of conduct for market participants. The group said that neither of the two can be optional if the industry wants to successfully accelerate its trade settlement system. The report came with a consultation that will remain open until the end of October 2024. A final report will be submitted to the government and regulators in December 2024.