Jurisdiction(s):
United Kingdom

Residence-based taxation of UK-resident settlors of offshore trusts from 6 April 2025: settlements and TAA code, TCGA s 86, FIG relief and TRF, with Budget 2025 technical amendments

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Practice notes

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 ‘available protected income’ rules and the transfer of assets abroad provisions, together with a transitional protection where those...

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Web page updated on 21/05/2026

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