Updated guidance published on key legislative changes
HMRC has also updated the relevant sections of their manuals with more detailed guidance as follows:
In September 2024, the Institute established a new working sub-group of the NI Tax Committee and Tax Committee South which is examining the complexity of cross-border and remote/hybrid working on the island of Ireland with a view to discussing the complexities of this with both the UK and Irish Government to identify improvements for employers and employees impacted.
New Inheritance Tax (IHT) residence based regime
From 6 April 2025, the UK’s IHT territoriality rules changed from a domicile to residence-based regime. Broadly, and subject to transitional provisions, individuals who have been UK tax resident for at least 10 out of the previous 20 tax years are now considered ‘long-term UK resident’ and are therefore subject to IHT on their worldwide assets. There are specific provisions relating to trusts.
Abolition of non-domiciled regime
The non-UK domiciled ‘remittance’ regime was abolished from 6 April 2025 and the new Foreign Income and Gains (FIG) regime was introduced. As a result, UK tax resident individuals now pay tax on worldwide income and gains on an arising basis irrespective of their domicile. This is subject to the four-year FIG regime which is available to individuals within their first four years of UK tax residence, after a period of at least 10 consecutive years of non-residence. These changes are also accompanied by a series of transitional rules which include the three-year Temporary Repatriation Facility for those previously taxed on the remittance basis.
HMRC has now published guidance to support these changes as follows:
Further HMRC guidance and manual updates are expected to be published in due course.
Update on consultation on predevelopment costs
In the 2024 Autumn Budget, the Government committed to launching a consultation in early 2025 to explore the tax treatment of predevelopment costs. Earlier this month, HM Treasury published an update on this which referred to the recent Court of Appeal judgment in Orsted West of Duddon Sands (UK) Ltd v HMRC .
According to HM Treasury, as this case considered “matters with significant readout across to this issue” the publication of this consultation has therefore been postponed. The Government will determine its next steps in respect to this consultation in due course.