UK taxation of offshore trust capital payments to UK-resident beneficiaries from April 2025: ARI/OIGs/s87 priority, TAA benefit charge, onward gift/close family, FIG and TRF
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FORTHCOMING CHANGES:
At Budget 2025 on 26 November 2025, the government outlined minor corrective changes to the residence-based tax system introduced by the Finance Act 2025. Key measures cover:
- eligibility for new arrivals under the foreign income and gains (FIG) regime, who must be at least 10 years old at the start of the tax year
- restricting FIG relief claims so they can be set only against the specific foreign income, foreign employment income, or foreign gains to which they correspond
- aligning the qualifying asset holding company (QAHC) rules so that carried-interest-style returns tied to services provided to a QAHC qualify for relief under the FIG regime
- a correction to the capital gains tax (CGT) residence test for personal representatives, ensuring 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 for an individual to file a tax return where they are not entitled to the CGT annual exempt amount under the FIG regime
- minor adjustments 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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