The UK’s New Residence-Based Tax Regime

Statutory Residence Test

• Automatic overseas residence
• Automatic UK residence
• ‘Sufficient ties’ tests
• Split-year treatment (overview)

Taxation of non-residents

• Availability of PA, etc
• Disregarded income calculations
• Non-resident landlord scheme (overview)
• Chargeability to CGT
• Temporary non-residence anti-avoidance, including:
• Autumn 2025 Finance Bill change
• Case studies

Taxation of UK residents

• Overview
• Qualifying new residents
• Definition
• Foreign income claims
• Foreign employment income elections
• Foreign gains claims
• Why it is not always beneficial to make these claims

Situs (location) of assets

Transitional provisions for non-doms who previously claimed remittance basis (overview)

• Temporary repatriation facility (TRF)
• Rebasing of assets for CGT purposes

The new residence-based IHT regime

• Definition of long-term resident (LTR), where worldwide assets come within the scope of IHT rather than just UK assets
• LTRs becoming non-resident
  • The ‘tail’ provisions
• Replacement of spousal domicile elections with spousal LTR elections

DTR, tax treaties and related issues (overview)

SA 106 and SA 109 forms

Our distinguished tax residency & domicile trainer is a chartered accountant who qualified with PwC in 1988, spending his final 18 months in the tax department. In 1989, he made a seamless transition to a leading financial training company as a tax tutor, where he began honing his teaching expertise. Since 1992, he has been self-employed as a Professional Tutor and Training Consultant, specialising in tax update courses tailored specifically for accountants, lawyers, and investment managers.

With decades of experience in both practical tax work and education, he has built a reputation for delivering insightful, up-to-date content that addresses the evolving needs of professionals in the tax and financial sectors.

In addition to being a leading tax residency & domicile educator, our expert trainer regularly contributes to Tax Insider and is a sought-after speaker at conferences hosted by prestigious organisations such as the ICAEW and CIOT.

This course will explain to delegates how someone’s residence status is determined, before explaining the key UK tax implications of being resident or non-resident. It is aimed at non-specialists, so will not cover advanced planning, but will explain the key issues for individuals resulting from the reforms in Finance Act 2025 (including the removal of the advantages of non-domiciled status).

• Redcliffe’s course trainer is a Chartered Accountant with over 35 years of experience in tax training
• Many practical scenarios will be discussed
• Short case studies will be included to help delegates understand the key issues
• The major reforms in April 2025 to the UK tax income tax, CGT and inheritance tax will be explained

Finance Act 2025 fundamentally changed the tax regime in the UK. The previous advantages of non-domiciled status for income tax, CGT and IHT were removed, with chargeability to all three taxes being based solely on a taxpayer’s residence status from 6 April 2025.

This course will assume no prior knowledge of the topic. After explaining how an individual’s UK residence status is established, we will discuss how the new regime applies, in particular the claims and elections available to ‘qualifying new residents’. We will also cover the key transitional rules for those who were previously non-domiciled in the UK.

Note that only UK tax rules will be discussed, not the tax law in other jurisdictions.