9 Stone Buildings

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Graham Callard
Graham Callard

9 Stone Buildings

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1 Contributions by 9 Stone Buildings Experts

UK IHT residence-based regime: excluded property trusts—long-term residence, relevant property charges, QIIP, GWR/POAT, treaty relief and transitional rules from 6 April 2025 (including Budget 2025 cap)
PRACTICE NOTES
UK IHT residence-based regime: excluded property trusts—long-term residence, relevant property charges, QIIP, GWR/POAT, treaty relief and transitional rules from 6 April 2025 (including Budget 2025 cap)
FORTHCOMING CHANGES: At the Budget on 26 November 2025, the government set out minor corrective adjustments to the residence-based tax regime introduced by Finance Act 2025. Key points are: new residents wishing to use the foreign income and gains (FIG) regime must be at least 10 years old at the start of the tax year relief claims under the FIG regime can be offset only against the specific foreign income, foreign employment income or foreign gains to which they relate alignment of the qualifying asset holding company (QAHC) rules so that carried-interest-style returns connected with services to a QAHC qualify for relief under the FIG regime a correction to the capital gains tax (CGT) residence test for personal representatives to ensure they are not UK resident where the deceased was UK non-resident but was a long-term UK resident for
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