International HNW individuals face new considerations following the Autumn Budget

Since April 2025, individuals coming to the UK after 10 consecutive years of non-UK residence can potentially benefit from the new four-year Foreign Income and Gains (FIG) regime. During that period, qualifying foreign income and gains can be exempt from UK tax, including when those funds are brought into the UK.

For internationally mobile entrepreneurs, investors and families, this can still make the UK an attractive proposition. However, the relatively short window means that planning for what happens after the four years is just as important as making use of the regime itself.

Once the FIG period comes to an end, worldwide income and gains are broadly subject to UK tax on an arising basis. There are also important inheritance tax considerations. Under the residence-based system introduced following the non-dom reforms, becoming a long-term UK resident can potentially bring worldwide assets within the scope of UK inheritance tax.

The Autumn Budget adds another issue to consider. From 6 April 2027, UK tax rates on savings income will increase to 24%, 44% and 49%, while equivalent new property income rates are also being introduced for England, Wales and Northern Ireland.

The Autumn Budget does, however, contain some potentially helpful measures for internationally mobile individuals. 

Trusts that become UK resident because a trustee moves to the UK will not face a CGT exit charge if they cease to be UK resident in the same or following tax year. This should remove a potentially significant tax consequence of a trustee’s temporary relocation. 

The government plans to introduce a foreign tax credit mechanism for UK resident members of US limited liability companies (LLCs) from 2028. This is expected to deal with the significant difficulties faced by the mismatch in classification between the UK (which views LLCs as opaque) and the US (which treats LLCs as transparent). 

Planning before moving to the UK

For HNW individuals considering UK residence, the key is therefore to plan before arrival rather than deal with each tax change in isolation.

A pre-arrival review should consider residence and the timing of a move, FIG eligibility, offshore structures and trusts, business interests and shareholdings, property and investment portfolios, as well as succession planning and potential inheritance tax exposure. For US-connected individuals, the interaction between the UK and US tax treatment of structures such as LLCs should also form part of that review.

It may also be appropriate to consider whether disposals or restructuring should take place before becoming UK resident.

Think beyond the first four years

For those eligible for the FIG regime, the four-year period can provide valuable planning opportunities. But it is important not to focus exclusively on those first four years.

The regime is only available following the required ten consecutive years of non-UK residence, so individuals should consider from the outset what their position could look like in year five.

For those intending to remain in the UK longer term, that means modelling the potential impact of worldwide income and gains taxation, inheritance tax, business ownership, property, pensions and family succession well in advance.

The central message is that the UK can still offer opportunities for internationally mobile individuals, but the rules increasingly reward forward planning. Decisions made before arrival, during the four-year FIG window and ahead of longer-term UK residence need to be considered together rather than as separate planning exercises. With the UK competing to attract international investment, entrepreneurs and capital, maintaining an attractive environment for internationally mobile individuals remains important. Irwin Mitchell’s latest Foreign Direct Investment report explores the wider factors shaping the UK’s international competitiveness.

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