Policy paper

Residence-based tax regime: technical amendments

This tax information and impact note is about technical amendments to the residence-based tax regime introduced in the Finance Act 2025.

From:
HM Revenue & Customs
Published
26 November 2025
Last updated
3 March 2026 — See all updates

Documents

Technical amendments to the residence-based tax regime

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Draft legislation

PDF, 253 KB, 19 pages

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Draft legislation (accessible version)

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Details

This measure is a collection of corrective amendments to the broader residence-based tax regime established in the Finance Act 2025. This is to make sure it operates as originally intended, without changing the underlying policy position.

This measure include amendments across a number of duties including:

  • Income Tax
  • Capital Gains Tax
  • Inheritance Tax

Updates to this page

Published 26 November 2025
Last updated 3 March 2026 href="#full-history">+ show all updates

  1. Information about ‘Who is likely to be affected’ has been updated for Individuals and trustees within scope of the Offshore Income Gains (OIG) provisions. Information about ‘General description of the measure’ now includes additional information about the Offshore Funds (Tax) Regulations 2009. Information about ‘Current law’ has been updated with details of the tax treatment of offshore funds.

  2. First published.

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