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)
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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 inheritance tax purposes
- a requirement that an individual must file a tax return where they are not entitled to the CGT annual exempt amount under the FIG regime
- minor changes to the ‘available protected income’ rules and to the transfer of assets abroad provisions, and a transitional protection where those...
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Web page updated on 22/05/2026
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Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
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