January 29, 2026

Article

The Autumn Budget delivered on 26 November 2025 bought meaningful changes for internationally mobile individuals, non-residents and those with cross-border assets. Whilst the Budget did not bring the impactful overhaul speculated about in the media, the measures announced do signal a continued tightening of rules affecting overseas income, offshore structures, and UK property ownership. 

Below are some of the key measures announced: 

UK Property Income Tax Rates

In November 2025, the Chancellor announced increases to rates of tax applicable to savings, dividend and property income. In most cases, UK property income remains taxable in the UK wherever you reside for tax purposes, due to the property being in the UK. A 2%-point tax increase will apply with effect from 6 April 2027.

Non-Resident Capital Gains Tax (NRCGT)

The rules around NRCGT are being tightened, with loopholes closing for indirect disposals.

This, together with increased tax rates applicable to property income, mean that the burden on UK property owners is growing, and existing structures may need reviewing to ensure that continued efficiency is obtained. 

Temporary Non-Residence

The government is taking further steps to ensure that internationally mobile individuals face consistent UK tax treatment using adjustments to the temporary non-residence anti-avoidance legislation. This anti-avoidance legislation applies where the following two conditions are met on your return to the UK:

  • You were tax resident for four out of the seven tax years immediately before year of departure; and
  • Your period of non-residence is less than five years 

Where these two conditions apply, you will be subject to UK tax in the year that you return to the UK on certain sources of income and capital gains that arose during your period of non-residence. From 6 April 2026, these rules are tightening further, to include any close company distributions. 

Restrictions to Voluntary National Insurance

Up until 6 April 2026, expats can pay voluntary class 2 National Insurance to secure full entitlement to the UK State Pension as well as other benefits. 

From 6 April 2026, class 2 voluntary contributions will be withdrawn, aiming to close gaps in the voluntary National Insurance system. Any expats currently relying on voluntary NI to maintain their State Pension record will face reduced access and higher contribution costs from 6 April 2026 so proactive planning is a must. 

If you are planning to leave or return to the UK, it is vital that you plan for this accordingly to avoid any unintended tax implications. 

Offshore Trusts and Inheritance Tax

A £5million cap will apply to ten-year anniversary and exit charges on certain excluded property trusts created before 30 October 2024. 

By way of a reminder, an excluded property trust was a mechanism whereby non-UK domiciled individuals could place their non-UK assets within an offshore trust structure to ensure that these assets remain outside the scope of UK Inheritance Tax. 

There have been a lot of changes that impact excluded property trusts in recent years so please do get in touch if you would like to discuss. 

Conclusion

The Autumn 2025 Budget continued the UK’s trend of tightening tax rules and closing loopholes. It is more important than ever that everyone reviews their UK tax exposure to ensure that affairs are structured as efficiently as possible. 

If you would like tailored advice on how these measures may impact your tax position or planning, please do get in touch.

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