E1.1122 Transfer of assets abroad—onward gifts rules: introduction
Following Finance Bill 2025, significant changes are made to the onwards gift regime due to the ending of remittance basis and non-UK domicile status from 6 April 2025.
The onward gifts rules until 5 April 2025 were directed at non-UK domiciled individuals and remittance basis users, especially where an overseas trust had been set up by a non-UK domiciled individual1.
From 6 April 2025, the focus shifts to qualifying new residents, who are entitled to make a foreign income election, under which overseas income can be exempt from UK taxes, and to non-UK residents2.
Transitional provisions are needed to address cases where remittance basis applied historically, and also, following Brexit, the cessation of the exemption from charge for income arising within the EU3.
These rules are discussed below, dealing with the rules applying from 2025/26 onwards first.
Onward gifts from non-residents or qualifying new residents
A benefit charge arises where a benefit is provided to an individual out of
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Web page updated on 17 Mar 2025 14:25