As of 6 April 2026, the new UK tax year is now in effect and while headline tax rates may appear largely unchanged, the reality is far more complex.
For individuals and businesses, particularly those with cross-border structures or international income streams, the cumulative effect of recent changes is creating a significantly more demanding tax environment.
This is not a year defined by a single reform, but by the interaction of multiple structural shifts.
A System Growing in Complexity
The UK tax system has long been considered one of the most intricate globally. However, in recent years, complexity has not only increased it has become more impactful.
Seemingly incremental changes to:
• Income tax thresholds
• Dividend allowances
• Capital gains tax exemptions
are now having a disproportionate effect on overall tax exposure, particularly when layered across international structures.
A key driver of this is fiscal drag. With personal allowances and thresholds frozen until 2030/31, more individuals are being pulled into higher tax bands despite no change in nominal rates.
For example, income between £100,000 and £125,140 can effectively be taxed at a marginal rate of 60% due to the tapering of the personal allowance.
Structural Reform: The End of Non-Dom and the FIG Regime
One of the most significant changes impacting internationally mobile individuals is the abolition of the remittance basis from April 2025.
In its place, the UK has introduced the Foreign Income and Gains (FIG) regime.
Under this system:
• New UK residents (after 10 years of non-residence) can benefit from a 4-year window
• During this period, foreign income and gains may be sheltered from UK tax
• After the window closes, worldwide income becomes fully taxable
For many clients, the 2026/27 tax year is when the full implications of this transition are being felt for the first time.
The Temporary Repatriation Facility (TRF)
Alongside the FIG regime, the Temporary Repatriation Facility (TRF) provides a limited opportunity for former remittance basis users.
This allows previously sheltered foreign income and gains to be brought into the UK at preferential rates:
• 12% for 2025/26 and 2026/27
• 15% for 2027/28
After this, the facility closes.
While this presents a clear planning opportunity, it also introduces risk. The definition of “remittance” remains broad and includes not only direct transfers but also indirect use of funds within the UK.
Careful structuring and timing are therefore essential.
Inheritance Tax: A Shift to a Residence-Based System
Inheritance tax (IHT) has also undergone a fundamental shift.
The UK has moved toward a residence-based system, meaning that individuals who have been UK resident for 10 out of the last 20 years may now be subject to IHT on their worldwide assets.
In addition:
• The nil-rate band remains at £325,000
• The residence nil-rate band remains at £175,000
• However, Business Property Relief (BPR) and Agricultural Property Relief (APR) are now capped at £2.5 million per individual
Assets above this threshold may face an effective 20% inheritance tax exposure, where previously they may have been fully exempt.
For business owners and internationally structured families, this represents a material change in estate planning.
Capital Gains Tax & Business Exits
While capital gains tax rates remain broadly stable:
• The annual exemption is now just £3,000 (down significantly from prior years)
• Business Asset Disposal Relief (BADR) rates increase to 18% from April 2026
For founders and investors, timing of disposals has become more critical than in previous years.
Corporate & Business Considerations
For companies:
• Corporation tax remains at 25% for profits above £250,000
• Employer National Insurance contributions remain elevated at 15%
For businesses establishing or expanding UK operations, the interaction between:
• Corporate tax
• Dividend extraction
• Personal tax exposure
requires careful upfront modelling.
From Static Planning to Ongoing Structuring
Perhaps the most important shift is not a specific tax change — but a change in approach.
The traditional model of:
“Set up a structure and revisit occasionally”
is no longer sufficient.
Instead, the current environment requires:
• Continuous review of structures
• Alignment across jurisdictions
• Forward-looking, proactive planning
Tax is no longer a back-office compliance function.
It is a core strategic consideration.
Why This Matters for International Clients
For globally mobile individuals, founders, and cross-border businesses, UK tax changes rarely operate in isolation.
Even minor adjustments can:
• Impact the efficiency of holding structures
• Change profit extraction strategies
• Create unintended multi-jurisdictional exposure
• Require alignment between personal and corporate planning
In short, local changes now have global consequences.
How Porte Consulting Approaches This
At Porte Consulting, the focus is on turning regulatory complexity into structured clarity.
This includes:
• Cross-border tax structuring
• International accounting coordination
• Integrated personal and corporate planning
Rather than addressing tax changes in isolation, the approach is to embed them within a broader, long-term strategic framework.
Final Thought
The 2026/27 UK tax year is not defined by a single headline reform,
but by the accumulation of multiple smaller changes.
And in today’s environment,
those incremental shifts are exactly what reshape the bigger picture.
Understanding the rules is no longer enough. Understanding how they interact is what truly matters.