The current remittance basis tax regime will be replaced by a residence based regime from 6 April 2025.

Foreign Income And Gains

Existing non domiciled individuals who have been resident in the UK for less than 4 years will be able to take advantage of the new scheme which provides for tax free foreign income and gains for up to the first four years of residence.

Longer term UK residents (greater than four years) will have to pay tax on all foreign income and gains from 6 April 2025.  However, transitional arrangements will mean that:

• For the 2025/26 tax year they will only pay UK tax on 50% of their foreign income arising in that year;
• Foreign income and gains arising before 6 April 2025 will be able to be remitted to the UK in the 2025/26 and 2026/27 tax years at a temporary 12% tax rate;
• Foreign assets will be able to be re-based to 5 April 2019 value for disposals after 6 April 2025
• Foreign income and gains arising on non-resident settlor interested trusts will not be taxed unless the income and or gains are paid to UK residents.

Overseas Workdays Relief

Non-UK domiciled individuals are currently able to claim tax relief for earnings from duties overseas for up to three years of UK residence – subject to not remitting the funds to the UK.

The Government is to consult on reforming the current regime.  However, it has been confirmed that the basic relief will remain, but the restriction on remittance will be removed.  This will be a welcome simplification for many.

Inheritance Tax

The Government will consult on changes to the inheritance tax regime in light of removing domicile and changing to a residence based regime.

However, to provide certainty, they have confirmed that the treatment of non-UK assets settled into a trust by a non-UK domiciled settlor prior to April 2025 will not change. 

Summary

It is clear that the Government’s intention is to encourage capital inflows into the UK rather than provide disincentives to do so.

However, many long term non domiciled UK residents will be significantly impacted from 6 April 2025 – although the 50% restriction on income and gains subject to tax for that year will be a welcome relief.

Less clear is the position around inheritance tax.  We would welcome clarification in this regard at the earliest opportunity.

Richard Feakins, Director of CST London, recently contributed to an article on the Australian Financial Review – UK’s new tax slug could force expat Aussies home – read Richard’s contribution here.

Boon Tan, Managing Director of CST in Singapore, recently joined Hemandra Tanapalan, Chief Executive Officer at Mstige Holdings, to discuss the intricate world of Web3. Together they unpack the tax implications of trading NFTs, investment strategies, and the vibrant community dynamics within the space.

In this podcast, Boon delves into topics such as DAOs, GameFI, and opportunities for additional income in Web3. Learn how to manage crypto and NFT profit taxes while navigating the evolving landscape of decentralized finance.

Listen to the podcast on Spotify.

To get the podcast transcript, click this link.

Our Managing Director in Singapore, Boon Tan, will be participating in Singapore Global Network’s “Relocation to Singapore” webinar.

The webinar is designed for foreigners relocating to Singapore, including job seekers, trailing spouses, and students.

Boon will be joined by Ms Marina Lopes, who has been residing in Singapore with her family since 2021. Boon and Marina will guide you through the process to ensure you embark on your Singaporean adventure with confidence.  

Hear from the personal experiences of those who have made the move, on various topics such as housing, transportation, children’s education, navigating work culture, social norms, and career options for trailing spouses.   

Whether you’re in the initial stages of planning or have already made the decision to relocate, we aim to assist you in assimilating seamlessly to our beautiful island, Singapore!  

Event sign up page: https://community.singaporeglobalnetwork.gov.sg/events/4585