Technical Amendments to Residence-Based Tax Regime

HMRC Policy Papers & Consultations

Published November 26th, 2025

Detected March 6th, 2026

Summary

HM Revenue & Customs has published technical amendments to the residence-based tax regime introduced in the Finance Act 2025. These amendments aim to ensure the regime operates as originally intended without altering the underlying policy. The changes affect Income Tax, Capital Gains Tax, and Inheritance Tax.

View original document View source feed page

What changed

HM Revenue & Customs (HMRC) has issued technical amendments to the residence-based tax regime, originally established by the Finance Act 2025. This policy paper, published on November 26, 2025, and last updated on March 3, 2026, clarifies that these are corrective amendments designed to ensure the regime functions as intended, without changing the core policy. The amendments span Income Tax, Capital Gains Tax, and Inheritance Tax, with specific updates noted regarding Offshore Income Gains (OIG) provisions and the tax treatment of offshore funds.

These amendments are primarily for individuals and trustees affected by the OIG provisions. While the changes are described as technical and corrective, ensuring compliance with the updated legislation is necessary. The document provides draft legislation in both accessible and standard formats. No specific compliance deadlines are mentioned, and the changes are presented as clarifications rather than new obligations, suggesting a routine operational adjustment for affected taxpayers and their advisors.

What to do next

Review the technical amendments to the residence-based tax regime for potential impact on Income Tax, Capital Gains Tax, and Inheritance Tax obligations.
Consult the draft legislation provided for detailed understanding of specific changes, particularly concerning Offshore Income Gains (OIG) provisions and offshore funds.
Ensure internal tax policies and systems are aligned with the clarified provisions of the Finance Act 2025.

Source document (simplified)

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 Get emails about this page

Documents

Technical amendments to the residence-based tax regime

HTML

Draft legislation

PDF, 253 KB, 19 pages

This file may not be suitable for users of assistive technology.

Request an accessible format.

If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Draft legislation (accessible version)

HTML

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 show all updates
1.
3 March 2026

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.
26 November 2025

First published.