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 allowances
• Disregarded income calculations
• Non-resident landlord scheme (overview)
• Chargeability to CGT
• Temporary non-residence anti-avoidance, including:
• Finance Act 2026 change
• Case studies

Taxation of UK residents

• Overview
• Qualifying new residents
• Definition
• Foreign income claims
• Foreign employment income elections
• Foreign gains claims
• Why is it 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), whose worldwide assets, rather than just UK assets, come within the scope of IHT
• 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. In 1989, he began working for a leading financial training company as a tax tutor. 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, 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.

Additionally, our expert trainer regularly contributes to Tax Insider and speaks at conferences hosted by prestigious organisations such as the ICAEW and CIOT.

• Explain how someone’s residence status is determined
• Discuss the anti-avoidance rules affecting temporary non-residents
• Explain the main UK tax implications of being non-resident (NR).
• Demonstrate the tax savings for NRs available from disregarded income calculations
• Explain the special claims and elections that are available to ’qualifying new residents’
• Review the main transitional rules for those previously non-domiciled individuals
• Explain the key facets of the UK’s residence-based IHT regime
• Ensure that non-specialists understand the key issues for individuals resulting from the reforms in the Finance Act 2025

nance 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’ will be discussed. 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.