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Imperial & Legal

UK taxes and international tax planning 

Assessment of your tax residence status, a calculation for every applicable tax, HMRC reporting and planning — from preparing to move to passing assets on.

25% corporation tax main rate
4 years of FIG regime relief
£325,000 inheritance tax threshold

What you owe in the United Kingdom depends on your tax residence status and on how many years you have already lived in the country, not on your nationality. Domicile stopped driving the taxation of income and gains on 6 April 2025, and on 6 April 2026 dividend rates and inheritance tax reliefs changed again. Below are the rates and thresholds in force for the 2026/27 tax year, together with the practical question of how to build an international tax strategy before the move rather than after the first letter from HMRC.

Who pays UK tax and on what

The scope of your liability is set by UK tax residence, not by your passport or the place where a company is registered. A UK tax resident is generally taxable on worldwide income and gains. A non-resident is taxable only on UK-source income — rent from a UK property, the profits of a permanent establishment, or gains on the disposal of UK land and property.

Residence is settled by a formal set of rules, the Statutory Residence Test. It has three parts, applied strictly in order: the automatic overseas tests, the automatic UK tests, and the sufficient ties test.

  • Automatically non-resident — if you were resident in one or more of the three preceding years and spent fewer than 16 days in the UK; if you were not resident in any of the three preceding years and spent fewer than 46 days; or if you work full time overseas.
  • Automatically UK resident — if you spend 183 days or more in the UK in the tax year; if the only-home test is met; or if you work full time in the UK.
  • Sufficient ties test — where neither set of automatic tests gives an answer, day counts are read against five ties: family, accommodation, work, the 90-day tie and, for leavers, the country tie.

The UK tax year does not follow the calendar: it runs from 6 April to 5 April the following year, while a company may choose its own accounting reference date. A fuller breakdown of the day counts and ties sits on the tax residence test page, and the long-term view for wealthy families is covered under tax planning for high-net-worth individuals.

Tax advice in the United Kingdom does not begin with a return but with a residence calculation, because that is what decides which income is reportable at all. From there the horizon stretches over years — the four-year relief, the tenth year of residence, the transfer of assets to the next generation. Imperial & Legal supports clients across that whole path, from the first assessment of status to the annual review.
Vasily Kluev
Client Service Director, Immigration Adviser (IAA)

Income tax and dividend rates in 2026/27

Income tax is charged on a progressive scale. The personal allowance is £12,570 and is withdrawn by £1 for every £2 of adjusted net income above £100,000, so it is gone entirely at £125,140. Rates and thresholds are frozen until 5 April 2031, which means more income falls into the upper bands each year even though the rates themselves do not move.

Income band (England and Northern Ireland)Rate
Up to £12,570 — personal allowance0%
£12,571 – £50,270 — basic rate20%
£50,271 – £125,140 — higher rate40%
Above £125,140 — additional rate45%

Dividends have their own scale, and the two lower rates rose by two percentage points on 6 April 2026: 10.75% within the basic rate band, 35.75% within the higher rate band and 39.35% at the additional rate. The dividend allowance is £500 a year. For an owner-manager drawing income as dividends this is a direct increase, and the familiar salary-versus-dividend split is worth recalculating. Current rates are published on GOV.UK.

Bank interest is taxed after the personal savings allowance: £1,000 for basic rate taxpayers, £500 for higher rate taxpayers and nil at the additional rate. Separate higher rates for savings and property income have been announced for 6 April 2027 — they are not yet in force for this tax year, but they belong in any planning around a rental portfolio. The full table of allowances sits on GOV.UK.

The FIG regime replaced non-dom status

The remittance basis, under which a non-domiciled resident paid UK tax on foreign income only when it was brought into the country, was abolished on 6 April 2025. In its place is the four-year foreign income and gains regime, a relief aimed at people who are only now becoming UK resident.

  • You qualify if you were non-resident in the UK for at least 10 consecutive tax years immediately before becoming resident.
  • The relief covers the first four years of UK residence, cannot be extended, and unused years are not carried forward.
  • It applies to foreign income and gains: dividends, interest, profits of an overseas trade and income from letting property abroad.
  • A claimant gives up the income tax personal allowance and the capital gains tax annual exempt amount.
  • The claim is made through the tax return and can be made source by source rather than for everything at once.

For capital built up under the old regime there is a transitional route, the Temporary Repatriation Facility. It allows previously untaxed foreign income and gains to be designated at 12% in 2025/26 and 2026/27 and at 15% in 2027/28, and it closes on 5 April 2028. For employees working in the UK for an overseas employer, Overseas Workday Relief runs for up to four tax years and is capped at the lower of £300,000 or 30% of qualifying employment income. The eligibility conditions are set out in HMRC guidance.

Advantages of instructing Imperial & Legal on UK tax matters

  • Assessment of residence status before the move, not after year one
  • Calculation of the liability for each tax across your asset structure
  • Eligibility check for the four-year FIG regime and a correct claim
  • Preparation and filing of tax returns within statutory deadlines
  • Handling of correspondence and enquiries raised by HMRC
  • Co-ordination of UK and overseas reporting obligations
  • Review of the strategy when residence, marriage or ownership changes
Tax adviser going through documents with a client across a meeting table in an office

Corporation tax and other business taxes

A resident company pays corporation tax on its worldwide profits; a company is resident if it is incorporated in the UK or centrally managed from it. A non-resident company is taxable on the profits of a UK permanent establishment and on gains from UK property. There is no longer a single rate — since 2023 a two-tier scale applies, with marginal relief bridging the gap.

Profits for the financial yearCorporation tax rate
Up to £50,000 — small profits rate19%
£50,000 – £250,000 — with marginal relief26.5% effective marginal rate
Above £250,000 — main rate25%

Both limits are divided by the number of associated companies in the group and reduced proportionately for an accounting period shorter than a year — one of the most common reasons for an unexpected assessment. Profits from patented inventions may qualify for the Patent Box and an effective rate of 10%. The complete table is published on GOV.UK.

Dividends received by a UK holding company from subsidiaries at home or abroad are normally exempt from corporation tax where the conditions of the distribution exemption are met. The rules differ for small companies and for medium and large ones, and anti-avoidance provisions apply in both cases, so a holding structure is best reviewed before a distribution rather than after it.

Beyond corporation tax an employer pays national insurance: the secondary Class 1 rate is 15%, the secondary threshold is £5,000 a year, and the Employment Allowance for eligible employers is £10,500. A separate set of duties sits with Companies House: an annual confirmation statement, accounts within nine months of the year end, and identity verification for directors and people with significant control, a legal requirement since 18 November 2025. The day-to-day side is covered by accounting services, and the structural side by UK company registration.

VAT: rates, thresholds and digital reporting

The standard rate of VAT is 20%. The reduced rate of 5% applies to a limited list of goods and services, including domestic energy and children’s car seats. Most food, children’s clothing, books and exports are zero-rated. Separately, some supplies are exempt — insurance, financial services, postage stamps and certain property transactions — which is not the same as zero-rated, because input VAT on exempt supplies cannot be recovered.

Registration is compulsory once taxable turnover in any rolling 12-month period exceeds £90,000, or if you expect to pass that figure in the next 30 days. The deregistration threshold is £88,000. Voluntary registration below the threshold can make sense when your customers are themselves VAT registered and the business carries significant input tax. Current thresholds are listed on GOV.UK.

VAT reporting is digital only: Making Tax Digital applies to every VAT-registered business regardless of turnover. Records must be kept in functional compatible software and transferred by digital links, with no manual re-keying between spreadsheets. Exemptions are narrow and have to be agreed with HMRC in advance.

Capital gains tax

Capital gains tax is charged on the profit made when an asset is disposed of — shares, a stake in a business, a second property, an interest in a partnership. Separate residential property rates were removed on 6 April 2025: individuals now pay 18% within the basic rate band and 24% above it. The annual exempt amount is £3,000, and it is not available to anyone claiming the FIG regime.

SituationRate for 2026/27
Individual within the basic rate band18%
Individual above the basic rate band24%
Trustees and personal representatives24%
Business Asset Disposal Relief (from 6 April 2026)18%, £1m lifetime limit
Companiesgains form part of profits and are taxed at the corporation tax rate

Property carries a separate obligation: a disposal of UK residential property must be reported and the tax paid within 60 days of completion, outside the ordinary return cycle. Non-residents must report every disposal of UK land and property, even where no tax is due. The 30-day deadline still quoted in many sources applied only to completions before 27 October 2021. The reporting procedure is set out on GOV.UK, and the transactional detail on the property taxes page.

Stamp Duty Land Tax on a property purchase

Stamp Duty Land Tax is paid once on the purchase of property or land in England and Northern Ireland and is charged on a sliding scale, with each rate applying only to its slice of the price. Scotland and Wales operate their own transaction taxes with different thresholds.

Portion of the priceStandard rateWith the additional dwelling surcharge
Up to £125,0000%5%
£125,001 – £250,0002%7%
£250,001 – £925,0005%10%
£925,001 – £1,500,00010%15%
Above £1,500,00012%17%

Worked example

On a purchase at £275,000 the duty is £3,750: nothing on the first £125,000, £2,500 on the next £125,000 and £1,250 on the remaining £25,000. If the property is not the buyer’s only dwelling, five percentage points are added to every band and the same purchase costs £17,500.

Buyers who are not UK resident for stamp duty purposes add a further two percentage points to every band, including the nil rate band. That surcharge can be reclaimed if the buyer later meets the day-count conditions for UK presence. Residential property above £500,000 bought by certain corporate bodies is charged at a flat 17% — raised from 15% on 31 October 2024 — with reliefs for property rental businesses, developers and several other trades. First-time buyers’ relief gives a nil rate up to £300,000 and 5% on the slice to £500,000, but is withdrawn entirely above £500,000. The official tables are on GOV.UK.

Tax advice and compliance

What an Imperial & Legal tax adviser works on

Establishing your tax status

Residence assessed under the SRT and an eligibility check for the FIG regime.

Planning before the move

A review of assets and income streams while the arrival date still leaves options.

Returns and reporting

Self Assessment, 60-day property returns and corporate filing obligations.

Succession and asset transfer

Inheritance tax exposure assessed and wills drafted around the outcome.

Adviser working through tax figures on a calculator beside a laptop and financial statements

Inheritance tax and long-term residence

Inheritance tax is charged at 40% on the part of an estate above the nil-rate band. The nil-rate band is £325,000 and is frozen until 5 April 2031. A residence nil-rate band of £175,000 is available where the main home passes to direct descendants; it is reduced by £1 for every £2 by which the estate exceeds £2,000,000. Any unused proportion of both bands transfers to a surviving spouse or civil partner, so a couple passing a home to their children may have up to £1,000,000 free of tax. Where at least 10% of the net estate is left to charity, the rate falls to 36%.

The decisive change concerns whose worldwide assets fall within the charge. Since 6 April 2025 domicile has been replaced by a residence test: worldwide assets are in scope for anyone who has been UK resident for at least 10 of the previous 20 tax years. After leaving the UK the exposure continues for a further 3 to 10 years, depending on how many years of residence had accumulated. For anyone below that threshold, only UK-situated assets are charged.

  • Nil-rate band £325,000, frozen to 5 April 2031; rate 40%, or 36% with a 10% charitable legacy.
  • Residence nil-rate band £175,000 for a main home passing to direct descendants, tapered from £2,000,000.
  • Long-term resident test: 10 years of residence out of the previous 20, followed by a tail of 3 to 10 years.
  • From 6 April 2026 agricultural and business property relief is capped at £2.5m at the 100% rate, with 50% relief above it, and the unused allowance passes to a spouse.
  • Shares that are not listed on a recognised exchange, including AIM shares, attract 50% relief in all circumstances.
  • From 6 April 2027 unused pension funds will form part of the estate for inheritance tax.

The long-term residence test is explained in GOV.UK guidance, while the practical side — wills, trusts and ownership structures — is covered on the wills and inheritance page.

What to check before moving to the UK and during year one

  • Calculation of the residence start date and the day count for the year
  • Eligibility for the four-year FIG regime and the date it expires
  • An inventory of foreign income and assets held on the arrival date
  • Realisation of gains before the status changes, where that is cheaper
  • Ownership of property: personally, jointly or through a company
  • Years remaining until the long-term resident inheritance tax test
  • Double taxation agreements between the UK and the previous country

Filing deadlines and Making Tax Digital

A personal Self Assessment tax return is required where income has not been taxed at source: self-employment income above £1,000, rental income, foreign income, dividends and interest above the allowances, capital gains, and UK income received by a non-resident. Registration for the first time is due by 5 October following the end of the tax year.

  • Paper return for 2025/26 — by 31 October 2026.
  • Online return for 2025/26 — by 31 January 2027.
  • Balancing payment of tax — by 31 January 2027.
  • Payments on account — 31 January and 31 July.
  • A £100 penalty applies immediately after the deadline, then £10 a day after three months and further penalties at 6 and 12 months.

Making Tax Digital for Income Tax took effect on 6 April 2026. Digital records and quarterly updates are compulsory for sole traders and landlords with qualifying income above £50,000, measured on the 2024/25 return. The threshold falls to £30,000 in April 2027 and to £20,000 in April 2028. The eligibility conditions are set out in HMRC guidance, and the filing dates on GOV.UK.

Not sure which returns your situation requires this year?

Imperial & Legal is a London law and tax firm advising private clients and businesses on UK and international taxation. Discuss your circumstances with an adviser.

How work with a tax adviser is structured

The work is not a form filled in each January. It starts with an assessment of status and continues as an annual review, because the position shifts with every additional year of residence, every change in the asset base and every change in family circumstances. What follows is the usual route through tax optimisation and advice.

Duration: 1–2 weeks
Assessment of tax status and current obligations

Assessment of tax status and current obligations

Duration: 1–2 weeks
The first meeting establishes the facts: days spent in the UK, the composition of income and assets, previous residence and any filings already made. An Imperial & Legal adviser applies the Statutory Residence Test and checks eligibility for the four-year FIG regime. From you it needs travel records, income sources and ownership details. The outcome is a clear map of obligations and exposure.
Duration: 2–4 weeks
Modelling the liability and choosing a strategy

Modelling the liability and choosing a strategy

Duration: 2–4 weeks
Each scenario is costed across income tax, capital gains tax and inheritance tax. The options are compared side by side: whether to claim the FIG regime, whether to realise gains before or after the change of status, whether to hold property personally or through a company. Imperial & Legal produces the calculations and written recommendations. From you it needs a decision on the chosen route.
Duration: 1–3 months
Preparing and filing returns with HMRC

Preparing and filing returns with HMRC

Duration: 1–3 months
Supporting documents are gathered, the Self Assessment return is completed and, where a property has been sold, the 60-day return is filed as well. Relief under double taxation agreements is applied where available. Imperial & Legal submits the returns and handles correspondence with HMRC. From you it needs statements and transaction paperwork. The outcome is filed returns and a calculated liability.
Duration: up to 12 months
Support with transactions and company obligations

Support with transactions and company obligations

Duration: up to 12 months
Individual events arise through the year: a property purchase with its stamp duty and surcharges, VAT registration, company filings with HMRC and Companies House, a dividend distribution. Each is checked for tax consequences in advance rather than afterwards. Imperial & Legal agrees the figures and the timetable; from you it needs the terms of the transaction. The outcome is obligations met on time.
Duration: annually
Annual review and succession planning

Annual review and succession planning

Duration: annually
Every year the residence count is updated, along with the time left on the FIG regime and the distance to the long-term resident threshold for inheritance tax. The strategy is adjusted for legislative change and family circumstances, and wills and transfer structures are put in place. Imperial & Legal runs this cycle on an ongoing basis. The outcome is a predictable position over the years ahead.

Situations that come up most often

The following situations account for most tax enquiries. Each has a clear answer when it is addressed before the event rather than after it.

  • Relocating while keeping an overseas business. An entrepreneur moves to the UK and continues to draw income from a company in the former country. The key question is eligibility for the four-year FIG regime and how the claim is made for each source.
  • Selling foreign property in the year of the move. The completion date relative to the start of residence decides whether a UK capital gains charge arises at all, and at what level.
  • A non-resident buying a first home in London. Two percentage points are added to the standard scale, and five more if another dwelling is owned anywhere in the world; the total can differ several times over.
  • Income arising in several countries. UK rules have to be read against the relevant double taxation agreements to establish where each stream is declared and where credit is due.
  • Approaching the tenth year of residence. Worldwide assets come into the inheritance tax net, and the ownership structure is best revisited before that point.

Client stories on tax matters

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Tax planning for married couple relocating to UK

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English tax return for a client with an Innovator visa

Santiago came to the UK from Costa Rica. We knew him from when he applied for his Innovator's visa to the UK. Imperial & Legal helped him to put together the necessary documents and...

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Tax planning for a foreign person when moving and buying a property in England

Pablo is originally from South America. He has been living in Britain for several years. His business involves supplying construction equipment to...

A comparable situation arose for a couple from Austria who moved to be near family while selling one home and buying another. This is how they described it themselves.

For sure, at our age, moving to another country is like a natural disaster. But after considering everything, we decided to move closer to Hannah's sister who lives in the UK. It was only later that we realised how many issues we had to handle — selling our old house, purchasing a new one, and dealing with taxes! We had no idea how to do it all properly, so we were grateful that Imperial & Legal assisted us.

Tobias and Hannah, 62 and 58 years old
A married couple from Austria
Clients’ names and photos have been changed

The mistakes that cost the most

Most assessments and penalties come not from elaborate structures but from a handful of ordinary errors. Every one of them is fixable in advance and almost impossible to fix afterwards.

  • Relying on superseded rules. There is still more published material about non-dom status and the remittance basis than about the FIG regime, although the old regime ended on 6 April 2025.
  • Counting days approximately. The residence test turns on exact figures — 16, 46, 90 and 183 days. No travel log is the most common cause of a dispute with HMRC.
  • Missing the 60-day property return. The duty arises independently of the annual return, and interest accrues from the first day it is late.
  • Overlooking associated companies. Corporation tax limits are divided between connected companies, so the small profits rate can stop applying without warning.
  • Assuming domicile still governs inheritance tax. Years of residence are what count now, and the tenth year arrives sooner than most people expect.
  • Leaving planning until late January. Most of the decisions that matter — the choice of regime, the timing of a disposal, the ownership structure — only work before the event.

Key takeaways

  • Liability follows UK tax residence under the SRT, not nationality.
  • The FIG regime replaced non-dom status: four years after ten years abroad.
  • Income tax is 20/40/45%; dividends from 6 April 2026 are 10.75/35.75/39.35%.
  • Corporation tax is 19% and 25%, with a 26.5% effective marginal rate.
  • Capital gains tax is 18% and 24%, with 60-day reporting on property.
  • Inheritance tax is 40% above £325,000, worldwide after ten years of residence.
  • The online return for 2025/26 is due by 31 January 2027.

The British tax system is neither the simplest nor the heaviest in Europe, but it is built so that most of the advantage goes to those who settled their position before the move or before the transaction. Once the event has happened the range of available answers narrows and the cost of an error rises — from a late filing penalty to the loss of a four-year relief that cannot be claimed retrospectively.

This page is for general information and does not replace individual advice: the rates and thresholds shown are those in force for the 2026/27 tax year, and how each rule applies depends on the particular facts. Below are the questions that come up most often at a first meeting.

UK taxes — frequently asked questions

When do I become a UK tax resident and how is that decided?

Residence is determined for a whole tax year under the Statutory Residence Test, not from the date you arrive. You are automatically resident if you spend 183 days or more in the UK during the tax year, or if the only-home test or the full-time work test is met. Where no automatic test applies, the sufficient ties test compares your day count against five ties: family, accommodation, work, the 90-day tie and, for leavers, the country tie. Split-year treatment can divide the year of arrival into a resident and a non-resident part, but the conditions for it are narrow and have to be checked case by case.

What replaced non-dom status and who qualifies for the new regime?

The remittance basis was abolished on 6 April 2025 and replaced by the four-year foreign income and gains regime. You qualify if you were non-resident in the UK for at least 10 consecutive tax years immediately before becoming resident. The relief covers the first four years of UK residence and removes the UK charge on foreign income and gains for that period. In exchange you give up the income tax personal allowance and the capital gains tax annual exempt amount, so for some people the claim is not worth making. It is made through the tax return and can apply to individual sources rather than all of them.

How are dividends from my UK company taxed in 2026/27?

Dividends have their own scale and are taxed after a £500 allowance. From 6 April 2026 the rates are 10.75% within the basic rate band, 35.75% within the higher rate band and 39.35% at the additional rate. The two lower rates rose by two percentage points compared with the previous year. For an owner-manager that means the customary balance between salary and dividends deserves a fresh calculation: once national insurance and corporation tax are taken into account, the efficient split may have shifted. The right answer depends on the total level of income and on the company’s own position.

Which rate of corporation tax applies to my company?

Profits up to £50,000 are taxed at the small profits rate of 19% and profits above £250,000 at the main rate of 25%. Between the two limits marginal relief applies, which makes the effective rate on each additional pound of profit 26.5%. Both limits are divided by the number of associated companies and reduced proportionately for accounting periods shorter than twelve months. That is the most frequent source of surprise: an owner of several small companies expects 19% and lands in the marginal relief band instead. Profits from patented inventions may qualify for the Patent Box and an effective rate of 10%.

When must I register for VAT and can I register earlier?

Registration is compulsory once taxable turnover in any rolling 12-month period exceeds £90,000, or if you expect to exceed it within the next 30 days. The deregistration threshold is £88,000. Voluntary registration below the threshold is possible and often worthwhile where your customers are VAT registered and the business incurs significant input tax that can be recovered. Every registered business must keep records in functional compatible software and file through Making Tax Digital, with digital links rather than manual transfers between spreadsheets. Exemptions from digital filing are narrow and require agreement with HMRC.

How quickly must I report the sale of a UK property?

The return is filed and the tax paid within 60 days of completion, separately from the annual Self Assessment return. The 30-day deadline still quoted in many places applied only to completions between 6 April 2020 and 26 October 2021. UK residents report disposals of residential property on which a gain arises; non-residents report every disposal of UK land and property, including commercial, even where the tax due is nil. Late filing attracts penalties and interest, so the calculation is best prepared alongside the conveyancing rather than afterwards.

How much stamp duty will I pay as a non-resident buyer?

Two percentage points are added to every band of the standard scale, including the nil rate band. If the property being bought is not your only dwelling — for example you already own a home abroad — a further five percentage points apply on top of that. The combined effect can be several times the headline figure. The non-resident surcharge can be reclaimed if you subsequently meet the day-count conditions for UK presence and claim within the time limit. Certain corporate bodies buying residential property above £500,000 pay a flat rate of 17% instead of the scale.

When do my foreign assets fall within UK inheritance tax?

Since 6 April 2025 domicile has been replaced by a residence test. Worldwide assets come within the charge for anyone who has been UK resident for at least 10 of the previous 20 tax years. Before that point only UK-situated assets are chargeable. After leaving the country the exposure continues for a further 3 to 10 years depending on the number of years of residence accumulated. The rate is 40% above the £325,000 nil-rate band, with an additional £175,000 available where the main home passes to direct descendants, and any unused proportion transfers to a surviving spouse.

Do I need to move to Making Tax Digital for Income Tax?

From 6 April 2026 digital records and quarterly updates are compulsory for sole traders and landlords with qualifying income above £50,000. The threshold is tested on the 2024/25 return and measured on gross income from self-employment and property, before expenses. It falls to £30,000 in April 2027 and to £20,000 in April 2028. Foreign income does not count towards the threshold. The annual Self Assessment return does not disappear: quarterly updates sit alongside it rather than replacing it, and the final declaration is still made after the end of the tax year.

What happens if I miss the 31 January filing deadline?

A £100 penalty applies immediately after the deadline, even if no tax is owed. After three months a daily penalty of £10 runs for up to 90 days, and at six and twelve months further penalties of 5% of the tax due or £300, whichever is greater, are charged. Late payment carries its own penalties of 5% of the unpaid tax at 30 days, six months and twelve months, together with interest for the whole period. A penalty can be appealed where there is a reasonable excuse, but the appeal has to be made within the time limit and supported by evidence.

Ready to put your UK tax position on a clear footing?

Imperial & Legal advises private clients and businesses on UK and international taxation, reporting obligations and succession planning. Discuss your circumstances with an adviser.

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