Transfer of assets abroad (TAA) regime meaning

FORTHCOMING CHANGES At the Budget on 26 November 2025, the government outlined small corrective updates to the residence-based tax rules introduced by Finance Act 2025. Key measures are: Newcomers seeking access to the foreign income and gains (FIG) regime must be at least 10 years of age at the start of the tax year. Claims for FIG relief are confined to offsetting the particular foreign income, foreign employment income or foreign gains to which they directly relate. Aligning the qualifying asset holding company (QAHC) framework so carried-interest-style returns connected with services provided to a QAHC benefit from FIG relief. Amending the capital gains tax (CGT) residence test for personal representatives so they are not UK resident where the deceased was UK non-resident but was a long-term UK resident for inheritance tax purposes. Introducing a requirement to file a tax return where an individual is not entitled to the annual exempt amount for CGT under the FIG regime. Minor revisions to the...

Practice Note: Tax and hedge funds—structuring the hedge fund vehicle When shaping how a hedge fund’s investment management should be arranged, the choice of legal vehicle for the fund itself—and, in particular, where it is formed—matters greatly. As discussed in Practice Note: Tax and hedge funds—structuring the hedge fund vehicle, a hedge fund vehicle can, in practice, adopt one of these structures: a Cayman Islands company a limited partnership an entity set up in another low (non-EU) tax jurisdiction (eg the Channel Islands, British Virgin Islands or Bermuda), or an entity or structure created under a special tax exemption regime in an EU or OECD member country (eg a Luxembourg SICAV or an Irish OEIC) This Practice Note explores the key tax issues when deciding how to organise the management of the fund’s investments. For these purposes, it is assumed that management is undertaken from the UK, which continues to be the centre of the European hedge fund industry. In...

Private Client England & Wales glossary A Abatement When, after settling the deceased’s funeral costs, debts and liabilities, the remaining estate cannot satisfy all legacies in full, the gifts are reduced accordingly, unless the Will shows a different intention. In a solvent estate, the order for reduction appears in Part II of Schedule 1 to the Administration of Estates Act 1925. Refer to Practice Note: Payment of legacies. Accruals basis Where income is taxed on an accruals basis, it is attributed to a given tax year by reference to the number of days within that year during which the activity giving rise to the liability accrued. See Practice Note: What is the basis of income tax?. Accumulation and maintenance (A&M) trust A form of non‑interest in possession trust designed to benefit children and young people up to 25, which received favourable inheritance tax treatment between 1975 and 2006. See Practice Note: Accumulation and maintenance trusts—IHT [Archived]. Accredited Legal Representative (ALR) ...