Recent changes to the UK tax regime affect anyone who:
- has an investment in the UK;
- was born in the UK but lives abroad;
- is a long-term UK resident who was not born in the UK.
Recent consequential changes to the UK tax system will affect both non-domiciled residents and domiciled individuals living abroad or in the UK. These changes create opportunities for some, while also posing significant risks for others. The previous system had been in place for many years and was one of the factors that made the UK attractive to high-net-worth individuals and investors.
While the advantages of non-domicile status have diminished over time, the latest reforms are prompting many people to review their UK tax position in relation to income, property, investments, residency, and status. In some cases, individuals are considering relocation to other jurisdictions with more favourable tax regimes.
Opportunities and pitfalls from the UK's new personal tax regime
- A new residence-based Foreign Income and Gains (FIG) regime was introduced on 6 April 2025. This changes how and when people are taxed, regardless of nationality or domicile. It introduces a 10+ year rule, alongside additional tax residency criteria.
- Worldwide Inheritance Tax (IHT) will apply only to long-term residents (more than 10 years). This creates opportunities for UK domiciles based overseas to restructure their investments but can present challenges for those moving to the UK.
- Relief from IHT for trading and farming businesses was restricted from 6 April 2024, reducing the attractiveness of the UK for some investors.
- The Statutory Residence Test and the four-year window of opportunity are now more critical than ever to monitor.
- A further UK Budget announcement is scheduled for 26 November 2025, which may introduce additional changes.
The road ahead
The current fiscal environment is challenging, and further reforms—including likely tax rises—are expected in the November Budget. It remains uncertain where the burden of such rises may fall.
It is essential for non-domiciles, UK domiciled individuals living abroad, and those who visit the UK regularly to review their tax positions. Failing to do so could result in unexpected tax liabilities. Conversely, careful planning may enable individuals to benefit from exemptions, particularly in relation to IHT. For those planning a future move to the UK—whether UK nationals or foreign nationals— preparation will be key to reducing future tax burdens.
Agenda
- Registration
- Speeches
Russell Brown•Alastair McQuater
Russell Brown
Vice chairman at AcclimeMr. Russell Brown OBE is Vice Chairman and Partner of Acclime Group, a regional corporate services firm. In 2001 Russell founded LehmanBrown International Accountants, a China‐focused accounting, taxation and business advisory firm employing around 200 professionals. LehmanBrown merged into Acclime Group in 2021. At LehmanBrown Russell was the Managing Partner.
Russell has over 39 years working experience including 32 years living in China and involved establishing and developing businesses in China, Hong Kong, as well as in Asia Pacific. Prior to founding LehmanBrown Russell was Global CFO of one of the world’s largest public relations and communications consulting companies with 72 offices worldwide, and prior to this their Asia Pacific Regional CFO covering 10 countries.
He currently acts as advisor to international companies entering the China market and to Chinese companies venturing abroad. He has advised in a wide range of industries and business situations in China and Hong Kong. He is also a frequent speaker at conferences and seminars on cross border taxation, accounting and doing business in and with China and Hong Kong. He also helps companies entering Asia Pacific and restructuring their operations and with regional risk management.
He is currently Treasurer of the Australian Chamber of Commerce in China. He has previously held various positions including Chair, Vice Chair and Treasurer of the British Chamber of Commerce in China, and is currently a co-opted board member. He was previously Vice Chair of the China‐Britain Business Council (CBBC), and Chair and Director of the Asia Transformation and Turnaround Association. He is also an Honorary Member of The 48 Group Club.
Russell gained a BA (Hons) in Business Studies from Bournemouth University, is a Fellow of the Chartered Institute of Management Accountants (CIMA) in the UK and a Fellow of the Institute of Chartered Accountants of England and Wales (ICAEW). He is also a Certified Global Management Accountant. Russell was awarded an OBE (Officer of the Order of the British Empire) for services to British Business and the British Community in China in Queen’s Birthday Honours in June 2015.
Alastair McQuater
Partner, Corporate Tax at BuzzacottAlastair leads Buzzacott’s Business Tax team and is a member of the firm’s Executive Board. He has been a partner in the firm since 2002.
Alastair’s practice focuses on structuring and transactional projects for a range of owner managed business, including companies, limited liability partnerships, and partnerships, working with clients to achieve their commercial aims in a practical and tax efficient manner.
Recent projects have included assisting vendors overcome a range of UK and overseas tax challenges to achieve successful business sales, structuring for a range of Search Fund and other business acquisitions, restructuring a significant investment in a research company so that EIS tax relief could be retained, and a number of business restructuring projects including complex partnership planning assignments.
- Networking Drinks
