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Legislation day 2025: Private client perspective

Tweaks rather than reversals.

New residence-based tax regime: FA 2025 fundamentally changed the UK tax regime for individuals formerly known as non-UK doms. The legislation enacting the various changes is extremely complex and given the time pressure for enactment inevitably littered with technical anomalies. Some tweaks have emerged in the L-Day papers published yesterday albeit we are reading from the Parliamentary Statement rather than draft legislation. We understand that:

  • The inheritance tax spousal election for non-long term UK resident spouses (i.e. those who are not within the scope of worldwide IHT) to benefit from the full spousal exemption where the spouse that has died was a long-term UK resident (thus within the scope of worldwide IHT). The legislation will be amended so the election lapses as intended after ten consecutive years of non-residence.
  • The Temporary Repatriation Facility was extended to income and gains pools with...

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