HMRC Updates
Income Tax: Personal allowance frozen at £12,570 CGT: Annual exempt amount is £3,000 NICs: Main Class 1 Employee NI rate reduced VAT: MTD system requirements fully enforced SDLT: First-time buyer relief threshold £425,000 Corporation Tax: Main rate 25% for profits over £250k IHT: Nil-rate band frozen at £325,000 Pension: Annual allowance set at £60,000
Cross-Border & Special Tax Situations 2026/27 | UK Tax Hero
Cross-Border & Special Situations · 2022/23–2026/27

UK Tax across
borders & beyond.

HMRC's published guidance on expat tax, the FIG regime, TRF, non-dom rules, cryptocurrency, side hustles and HMRC nudge letters — summarised with five years of official rates and direct links to GOV.UK sources.

HMRC sources only GOV.UK links throughout 5 years of rates Not financial advice

Cross-Border Tax Hub

🌐 2026/27
FIG regime (new residents)4 years tax-free
TRF rate 2025/26–2026/2712% flat
Crypto CGT (higher rate)24%
Trading allowance (gross)£1,000
Source: HMRC / GOV.UKUpdated May 2026
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HMRC sourced
GOV.UK links
5 years of rates
Information only
HMRC 2025/26–2026/27 figures

Key published rates.

All figures sourced from HMRC / GOV.UK. Always verify on GOV.UK before acting.

£3,000
CGT annual exempt amount 2025/26–2026/27 · GOV.UK
18/24%
Crypto CGT rates from 30 Oct 2024 · GOV.UK
12%
TRF flat rate 2025/26–2026/27 · RDRM73000
£1,000
Trading allowance (gross) · GOV.UK
HMRC guidance summary

Cross-border tax: what HMRC's rules say.

This page summarises HMRC's published guidance on cross-border and special situation tax rules. Every section links directly to the relevant GOV.UK source. It is not tax advice — for advice specific to your circumstances, speak with a qualified tax professional.

Domicile replaced by residence — what HMRC's guidance says

According to HMRC's published guidance on non-domiciled residents, the Finance Act 2025 abolished the remittance basis of taxation from 6 April 2025. The UK now operates a residence-based system: whether you pay UK tax on worldwide income and gains is determined by your residence status under the Statutory Residence Test (HMRC RDR3) — not by domicile.

The new framework published by HMRC has three main components:

  • Foreign Income and Gains (FIG) regime — HMRC's guidance confirms that individuals becoming UK resident after at least 10 consecutive years of non-UK residence may claim full relief on foreign income and gains for their first four tax years of UK residence.
  • Temporary Repatriation Facility (TRF) — documented in HMRC's manual RDRM73000, this is a time-limited window for former remittance-basis users to designate pre-April 2025 offshore funds and pay a flat charge of 12% (2025/26–2026/27) or 15% (2027/28). The TRF closes permanently after 5 April 2028.
  • Worldwide arising basis — from year five of UK residence, all individuals pay UK tax on worldwide income and gains as they arise, in the same way as any UK-domiciled resident.

📋 Key dates published by HMRC

  • 6 April 2025 — remittance basis abolished; FIG regime and TRF take effect. GOV.UK source
  • 2025/26 & 2026/27 — TRF designation rate: 12% on designated pre-April 2025 foreign income and gains. RDRM73000
  • 2027/28 — TRF rate rises to 15%; final year to designate under the facility.
  • 5 April 2028 — TRF closes permanently. After this date, remittances of pre-April 2025 FIG are taxed at full marginal rates (up to 45%).
  • 31 January 2028 — amendment deadline for 2025/26 Self Assessment returns. Designations for the 2025/26 year must appear on a return filed or amended by this date to secure the 12% rate.

HMRC's Statutory Residence Test — your starting point

Before any other cross-border question can be addressed, HMRC requires you to establish your residence status. HMRC's RDR3 guidance note sets out a three-part test:

Test typeHMRC conditionResultHMRC source
Automatic UK183+ days in UK in the tax yearUK residentGOV.UK
Automatic UKOnly home in UK 91+ consecutive days & visited 30+ daysUK residentGOV.UK
Automatic UKFull-time UK work for 365-day periodUK residentGOV.UK
Automatic overseasFewer than 16 days in UK (46 if not resident prior 3 years)Non-residentGOV.UK
Automatic overseasFull-time overseas work, <91 days in UK, ≤30 UK work daysNon-residentGOV.UK
Sufficient tiesIntermediate day counts + 1–5 UK tiesDepends on tiesRFIG20500

Cryptocurrency — HMRC's position

According to HMRC's Cryptoassets Manual (CRYPTO) on GOV.UK, cryptoassets are treated as property for tax purposes — not currency. Every disposal (selling, swapping, spending, gifting other than to a spouse) is a Capital Gains Tax event. HMRC's guidance further states that the situs (location) of a cryptoasset follows the beneficial owner's UK tax residence — not the jurisdiction of the exchange, server or storage device. This means UK tax residents are subject to UK CGT on all crypto disposals worldwide.

Side hustles and platform reporting

HMRC's published guidance on the trading allowance confirms the £1,000 gross threshold remains unchanged for 2025/26 and 2026/27. Separately, HMRC's platform reporting rules (DAC7) require digital platforms to report seller income to HMRC directly. HMRC confirmed in March 2025 that from 2027/28 a simplified reporting route will apply for gross trading income between £1,000 and £3,000, but the trading allowance itself remains at £1,000.

HMRC nudge letters and the WDF — HMRC's stated process

According to HMRC's published guidance on the Worldwide Disclosure Facility, where an individual has undisclosed offshore income or gains, the WDF is the correct and required route for making a disclosure — amending a Self Assessment return is not sufficient for offshore matters. HMRC's guidance also confirms that offshore penalties under the 'Requirement to Correct' legislation can reach up to 200% of the tax owed, but that voluntary unprompted disclosure substantially reduces this.

Illustrative example only

FIG regime — illustrative figures (not advice)

Tax year of UK arrival (year 1 of FIG)2025/26
Prior non-UK residence (qualifying)12 years
Hypothetical foreign investment income£85,000
UK tax on that foreign income if FIG claimed£0 (per HMRC FIG guidance)
UK salary (taxed on arising basis regardless)Standard UK rates apply
Verify your position with HMRC or a specialistGOV.UK →

This is a simplified illustration of how HMRC's FIG regime works in principle. Individual circumstances vary significantly. This is not tax advice — speak with a qualified adviser.

All topics

Your complete cross-border tax hub.

Each section summarises HMRC's published guidance with direct GOV.UK source links. None of this constitutes personal tax or financial advice.

🌍

Expats & UK Tax

HMRC's Statutory Residence Test, split-year treatment, foreign income reporting on SA106, double tax treaties and the FIG regime — as published on GOV.UK.

SRT · RDR3 · Split Year · SA106
Full expat guide →
🏛️

Non-Domiciled Residents

FIG regime, TRF (12%/15%), IHT 10-out-of-20 rule, mixed funds cleansing and trust structures — per HMRC's Finance Act 2025 guidance.

FIG · TRF · IHT · RDRM
Non-dom guide →

Cryptocurrency Tax

HMRC's Cryptoassets Manual: CGT on disposals, income tax on staking and mining, s.104 pooling rules, situs, CARF and SA108 reporting.

CRYPTO Manual · CGT 18/24% · CARF
Crypto guide →
💼

Side Hustles

HMRC's trading allowance rules, DAC7 platform reporting obligations, Self Assessment registration and MTD — as published on GOV.UK.

£1,000 allowance · DAC7 · MTD
Side hustle guide →
💳

TRF & Remittance

HMRC's Temporary Repatriation Facility: designate pre-April 2025 funds at 12%, mixed fund rules, TRF capital accounts (RDRM75000).

12% rate · RDRM73000–75500
TRF guide →
📬

HMRC Nudge Letters

What HMRC's 'one to many' letters mean, the Worldwide Disclosure Facility (WDF) as HMRC's required disclosure route, and offshore penalty rules.

CRS · DAC7 · WDF · Req. to Correct
Nudge letter guide →
🎯

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Cross-border tax is fact-specific. Our free matching service connects you with verified UK specialists — accountants and tax advisers — for personal advice on your situation.

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HMRC published rates 2022/23–2026/27

Five years of official figures.

Cross-border situations frequently involve prior-year returns and voluntary disclosures. All figures below are sourced from HMRC's published rates on GOV.UK.

CGT annual exempt amount & rates — all assets including crypto 📄 GOV.UK

Tax YearAnnual Exempt AmountCGT — basic rateCGT — higher/add. rateNotes
2022/23£12,30010%20%Pre-Budget 2024 rates
2023/24£6,00010%20%Halved by Spring Budget 2023
2024/25 (to 29 Oct 2024)£3,00010%20%Old rates: disposals before 30 Oct 2024
2024/25 (from 30 Oct 2024)£3,00018%24%Autumn Budget 2024 increase
2025/26£3,00018%24%Confirmed
2026/27£3,00018%24%Confirmed — no changes announced

Source: GOV.UK — Capital Gains Tax rates and allowances

Income Tax rates & Personal Allowance — England, Wales & NI 📄 GOV.UK

Tax YearPersonal AllowanceBasic rate (20%)Higher rate (40%)Additional rate (45%)
2022/23£12,570£12,571–£50,270£50,271–£150,000Over £150,000
2023/24£12,570£12,571–£50,270£50,271–£125,140Over £125,140
2024/25£12,570£12,571–£50,270£50,271–£125,140Over £125,140
2025/26£12,570£12,571–£50,270£50,271–£125,140Over £125,140
2026/27£12,570£12,571–£50,270£50,271–£125,140Over £125,140

Source: GOV.UK — Income Tax rates and allowances. Personal Allowance frozen until April 2031 per published HMRC policy.

TRF rates — HMRC's published schedule 📄 RDRM73000

PhaseTax YearsTRF Charge RateStandard rate (if not designated)Status
Phase 12025/26 & 2026/2712%Up to 45%Current — open now
Phase 22027/2815%Up to 45%Opens April 2027
Phase 3From 6 April 2028ClosedUp to 45%TRF closed permanently

Source: HMRC RDRM73000 and Finance Act 2025, Schedule 2.

Trading allowance & DAC7 platform reporting 📄 GOV.UK

Tax YearTrading Allowance (gross)SA registration thresholdPlatform (DAC7) reporting
2022/23£1,000£1,000Not yet in force
2023/24£1,000£1,000Platforms began data collection
2024/25£1,000£1,000First mandatory reports filed Jan 2025
2025/26£1,000£1,000Fully operational — HMRC receives data
2026/27£1,000£1,000 (£3,000 simplified route from 2027/28)CARF also active for crypto exchanges

Sources: GOV.UK trading allowance · GOV.UK DAC7 platform reporting

HMRC guidance: expats & SRT

UK tax for expats — what HMRC says.

According to HMRC's guidance on tax on foreign income, your UK residence status — determined under the Statutory Residence Test (RDR3) — determines whether you pay UK tax on worldwide income or only on UK-source income. HMRC's guidance states that non-residents pay UK tax only on UK-source income; UK residents pay on worldwide income.

⚠️ This is a summary of HMRC's published guidance — not advice

The SRT involves complex fact-specific analysis. HMRC publishes a free online residence status checker on GOV.UK. For anything beyond the automatic tests, speak with a qualified tax adviser.

Split-year treatment — HMRC's rules

According to GOV.UK, when you move in or out of the UK, the tax year may be split into a UK-resident part and a non-resident part — known as split-year treatment. HMRC's RDR3 guidance sets out eight specific 'cases' under which split-year treatment applies. It is not elective — your circumstances must meet the legal conditions. HMRC's guidance states you should claim it on the SA109 supplementary pages of your Self Assessment return.

Illustrative example only — not advice

Split-year treatment: leaving mid-year (illustrative)

UK resident portion (6 Apr–departure date)UK income taxed in UK
Non-resident portion (departure onwards)Foreign income not taxable in UK
UK-source income throughout yearAlways taxable in UK
Verify eligibility via HMRC's RDR3 guidanceRDR3 →

Individual circumstances vary. This illustrates the principle only. Always confirm your split-year case with a qualified specialist.

HMRC guidance: non-doms & FIG

The new non-domicile framework.

According to HMRC's published guidance on non-domiciled residents, the Finance Act 2025 abolished the remittance basis from 6 April 2025 — replacing it with a strictly residence-based system. Domicile is no longer relevant for Income Tax or CGT purposes from that date.

HMRC's 4-year FIG regime — qualifying conditions

Per HMRC's guidance, to qualify for the FIG regime an individual must:

  • Be UK resident under the SRT in the relevant tax year.
  • Have been non-UK resident for at least 10 consecutive tax years before their first qualifying year of UK residence.
  • Not be a member of the House of Commons or House of Lords.
  • Claim the relief annually on their Self Assessment return — it is not automatic.

HMRC's guidance confirms that during the 4-year FIG period, qualifying foreign income and gains may be brought to the UK at any time without any UK tax charge. In year five of UK residence and beyond, worldwide income and gains are taxed on the arising basis at standard rates.

⚠️ FIG regime — what HMRC says it does NOT cover

  • UK-source income — always taxable on the arising basis regardless of FIG status. GOV.UK
  • CGT on UK residential property — always taxable for UK residents.
  • Year 5+ of UK residence — FIG relief ceases; worldwide arising basis applies.
  • Years of non-residence — FIG cannot be claimed if not UK resident that year.
HMRC guidance: TRF

Temporary Repatriation Facility — HMRC's rules.

The TRF is documented in HMRC's internal manual RDRM73000 and legislated under Finance Act 2025, Schedule 2. It is available to former remittance-basis users who have pre-April 2025 untaxed foreign income and gains (FIG) offshore.

Designate now, remit later — HMRC's mechanics

A critical feature of the TRF — confirmed in HMRC's manual — is that designation on a Self Assessment return and payment of the TRF charge is all that is required to secure the discounted rate. The funds do not need to be physically moved to the UK at the time of designation. Once designated and the charge paid, those funds become 'TRF capital' and can be remitted to the UK at any future date — including after the TRF window closes on 5 April 2028 — with no further UK tax charge. See HMRC RDRM75100 for HMRC's definition of TRF capital.

📅 31 January 2028 — critical HMRC deadline

To secure the 12% rate for the 2025/26 tax year, HMRC's rules require the designation to appear on a Self Assessment return that is filed or amended by the amendment deadline of 31 January 2028. Designations made in the 2026/27 return (filed by 31 January 2027, or amended by 31 January 2028) also qualify for the 12% rate. The 15% rate applies to designations in the 2027/28 return only.

TRF and mixed offshore funds — HMRC's RDRM75000

According to HMRC's manual RDRM75100, special rules apply where offshore funds are held in 'mixed accounts' — accounts containing a blend of pre-arrival clean capital, taxable income and taxable gains. HMRC's guidance confirms that under the new Step A1 introduced by Finance Act 2025 (section 809Q ITA 2007), TRF capital is treated as remitted in priority to all other types of income and capital in a mixed fund. See RDRM75200 for the full mixed fund ordering rules.

HMRC's manual also provides for a TRF capital account — a nominated separate overseas bank account to which TRF capital can be transferred, keeping it separate from other funds and preventing it from being inadvertently spent offshore. See RDRM75310 for HMRC's rules on TRF capital accounts.

Illustrative example only — not advice

TRF designation: illustrative figures based on HMRC's published rates

Pre-April 2025 FIG designated (hypothetical)£500,000
TRF charge rate (2025/26 or 2026/27)12% per HMRC RDRM73000
TRF charge payable (illustrative)£60,000
Equivalent charge at additional rate (45%)£225,000 (illustrative)
Verify your position — speak with a qualified adviserFind a specialist →

This illustrates HMRC's published TRF rate only. Actual tax payable depends on individual circumstances, fund composition and eligibility. This is not tax advice.

⚠️ TRF window is time-limited

The 12% rate closes after 5 April 2027. The TRF closes permanently after 5 April 2028.

HMRC's guidance is clear: pre-April 2025 FIG designated after 2027/28 will be taxed at full marginal rates. If you hold untaxed offshore funds and were formerly a remittance-basis user, speaking with a qualified adviser who understands the TRF mechanics is important before the window closes.

HMRC guidance: cryptocurrency

HMRC's rules for cryptoassets.

According to HMRC's Cryptoassets Manual on GOV.UK, cryptoassets are treated as property — not currency — for tax purposes. HMRC's guidance states that almost every interaction with a cryptoasset creates a tax event. HMRC's manual also clarifies the situs rule: the location of a cryptoasset for UK tax purposes is determined by the beneficial owner's tax residence, not the jurisdiction of any exchange, server or storage device.

When HMRC says CGT applies

  • Selling crypto for fiat currency — disposal for CGT purposes. GOV.UK
  • Swapping one cryptoasset for another — HMRC treats each swap as a disposal of the first asset, valued in sterling at the date of the transaction. GOV.UK
  • Spending crypto on goods or services — disposal at market value at point of spending.
  • Gifting crypto (other than to a spouse or civil partner) — disposal at market value; CGT may apply.
  • NFTs — HMRC treats NFTs as cryptoassets; the same disposal rules apply.

When HMRC says Income Tax applies

  • Mining — HMRC's guidance states mining as a trade is subject to Income Tax and NICs on profits. GOV.UK
  • Staking rewards — HMRC treats staking rewards as miscellaneous income, taxable at the sterling value on the date received.
  • Airdrops — HMRC's guidance states that airdrops received in return for a service are subject to Income Tax; unsolicited airdrops may be treated as capital depending on circumstances.
  • Receiving crypto as salary — HMRC treats this as employment income (money's worth), subject to PAYE and NICs.
Illustrative example — based on HMRC's published rates

Crypto disposal — higher-rate taxpayer (2025/26, illustrative)

Disposal proceeds (hypothetical)£28,000
Section 104 pool cost (HMRC matching rules)£9,000
Gross gain£19,000
Annual exempt amount 2025/26 (HMRC)−£3,000
Taxable gain£16,000
CGT at 24% (higher rate per HMRC 2025/26)£3,840
Report on SA108 — verify with HMRC or specialistGOV.UK →

This applies HMRC's published rates to hypothetical figures. It is illustrative only and is not tax advice. Individual circumstances affect the outcome significantly.

🔍 CARF & HMRC data — what HMRC's guidance says

From 2026, HMRC's published guidance confirms that UK crypto service providers must report transaction data under the Crypto-Asset Reporting Framework (CARF). Combined with the Common Reporting Standard (CRS) data-sharing agreements with 100+ countries, HMRC receives transaction histories from global exchanges. HMRC's published guidance on the Digital Disclosure Service explains the process for correcting underdeclared gains.

HMRC guidance: side hustles

Side hustle tax — HMRC's published rules.

According to HMRC's published guidance on tax-free allowances, individuals may receive up to £1,000 of gross trading income per tax year without paying Income Tax or NICs — known as the trading allowance. HMRC's guidance states this is a gross figure (before expenses). There is no new tax on side hustles — the existing rules have always applied. What has changed is HMRC's access to data.

📱 HMRC's platform reporting rules (DAC7)

According to HMRC's published guidance on digital platform reporting, digital platforms (Airbnb, eBay, Etsy, Vinted, Uber, Deliveroo, Fiverr and others) must report seller income to HMRC annually under DAC7. First mandatory reports were filed in January 2025. HMRC now receives this data before taxpayers file their returns.

📅 Simplified reporting from 2027/28 — HMRC announcement

HMRC confirmed in March 2025 that from the 2027/28 tax year, a simplified online reporting process will apply to gross trading income between £1,000 and £3,000, replacing the requirement for a full SA100 for many in that band. The trading allowance (£1,000) itself does not change. GOV.UK trading allowance guidance

Illustrative example — not advice

Platform income: illustrative figures based on HMRC's published rates

Platform gross receipts (hypothetical Airbnb)£6,400
Allowable expenses (HMRC guidance)−£1,800
Taxable profit£4,600
Income Tax at 20% (hypothetical basic rate)£920
Report on SA100 + SA105 — verify on GOV.UKGOV.UK →

Illustrative only. Individual tax rates, allowances and circumstances vary. Not tax advice.

HMRC guidance: nudge letters & disclosures

HMRC nudge letters — what HMRC's guidance says.

HMRC's 'one to many' compliance letters (commonly called nudge letters) are issued when HMRC's data — from the Common Reporting Standard (CRS), DAC7 platform reports, CARF crypto data, or other risk indicators — suggests a possible discrepancy with a taxpayer's return. According to HMRC's published Worldwide Disclosure Facility guidance, where undisclosed offshore income or gains are identified, the WDF is the required route for making a disclosure. HMRC's guidance is explicit: simply amending a Self Assessment return is not the correct approach for offshore matters.

⚠️ HMRC's 'Requirement to Correct' legislation — published penalty range

HMRC's published guidance on offshore matters confirms that penalties under the Requirement to Correct regime can range from 30% to 200% of the tax owed depending on the category of territory and the nature of the failure. HMRC's guidance confirms that voluntary unprompted disclosure substantially reduces these penalties — typically to 0–30% for innocent errors in Category 1 territories. See GOV.UK: offshore penalty guidance.

What HMRC's published guidance says about the WDF process

According to GOV.UK's WDF guidance, the WDF is HMRC's online service for voluntarily disclosing undeclared offshore income, gains and assets. HMRC confirms that using the WDF before they contact you constitutes an 'unprompted' disclosure, which results in lower penalties. The facility is open indefinitely and is accessed through the HMRC Digital Disclosure Service.

Speak to a qualified specialist

Received an HMRC nudge letter or concerned about undisclosed income?

HMRC's guidance is clear about the WDF being the required route for offshore disclosures. If you have received a nudge letter or have concerns about undisclosed income from overseas accounts, crypto or digital platforms, a qualified tax adviser can assess your position and assist with any required disclosure. Our free matching service can connect you with verified UK specialists.

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Common questions

Cross-Border & Special Situations FAQs

Answers based on HMRC's published guidance, with direct GOV.UK source links. Not tax advice — speak with a qualified professional for advice specific to your situation.

What is the Statutory Residence Test (SRT)?
According to HMRC's RDR3 guidance note on GOV.UK, the SRT is a three-part framework that determines UK tax residence. You are automatically UK resident if you spend 183+ days in the UK, your only home is in the UK for 91+ consecutive days with 30+ days visited, or you work full-time in the UK for a 365-day period. You are automatically non-resident if you spend fewer than 16 days in the UK (46 days if not resident in the previous three years), or you work full-time abroad with fewer than 91 days in the UK. Between these automatic tests, HMRC's 'sufficient ties' test applies, depending on the number of connections you have to the UK.
How many days can I spend in the UK without becoming UK tax resident?
Per HMRC's GOV.UK guidance on residence, the number of days depends on your 'sufficient ties' to the UK. HMRC identifies five ties: family tie, accommodation tie, work tie, 90-day tie, and country tie. If you have no ties and were not UK resident in the previous three years, you may spend up to 45 days. With one tie, 120 days (not previously resident) or 45 days (previously resident). With three ties: 45 days. With four or five ties: 15 days. HMRC's RDR3 sets out the full table. Day counts should be verified against HMRC's RDR3 for your specific circumstances.
What is split-year treatment and how does HMRC say it works?
According to GOV.UK, split-year treatment divides a tax year into a UK-resident part and a non-resident part when you move in or out of the UK mid-year. During the non-resident part, foreign income is not taxable in the UK. HMRC's RDR3 sets out eight specific 'cases' — it is not an election; your circumstances must legally qualify. HMRC's guidance states the claim is made on the SA109 supplementary pages of a Self Assessment return. Full details are in HMRC's RDR3 guidance note.
How do I check my UK residence status?
HMRC provides a free online Residence Status Checker on GOV.UK covering tax years from 6 April 2016. You will need information about days spent in the UK, hours worked, family in the UK and any UK home. For complex situations — particularly where the sufficient ties test applies — HMRC's guidance recommends reading RDR3 in full or seeking professional advice.
How does HMRC say I should report foreign income?
According to HMRC's guidance on reporting foreign income, UK residents with foreign income must file a Self Assessment return using the SA106 (Foreign) supplementary pages. Foreign earnings, pensions, dividends, interest and rental income must all be reported by source country. Foreign tax paid can be claimed as a credit against UK tax under double taxation relief. Convert all amounts to sterling using the exchange rate at the date of receipt, or HMRC's agreed average rate for the year.
What is the five-year temporary non-residence rule?
HMRC's guidance on returning to the UK (GOV.UK) confirms that if you become non-resident and return to the UK within five complete tax years, certain gains on assets held when you left may become taxable in the year of return — this is the temporary non-residence rule. It generally does not apply to assets acquired after your departure. HMRC's guidance recommends careful planning around asset disposals during any short period of non-residence.
What replaced the non-domicile remittance basis from April 2025?
According to HMRC's published guidance on GOV.UK, the Finance Act 2025 abolished the remittance basis from 6 April 2025, replacing it with the Foreign Income and Gains (FIG) regime. Individuals who become UK resident after at least 10 consecutive years of non-UK residence may claim 100% relief on foreign income and gains for their first four tax years of UK residence. From year five of UK residence, worldwide income and gains are taxed on the arising basis at standard rates. Domicile is no longer relevant for Income Tax or CGT purposes.
Can I still claim the FIG regime if I became UK resident before April 2025?
Yes — per HMRC's guidance, eligibility is based on your residence history. If you first became UK resident after 10 or more consecutive years of non-UK residence, you can still claim FIG relief for remaining qualifying years after April 2025. For example, if you first became UK resident in 2023/24, you may claim for 2025/26 and 2026/27 (years three and four). The FIG clock runs from your first year of UK residence, not from April 2025.
What is HMRC's new 10-out-of-20 Inheritance Tax rule?
According to HMRC's published guidance, the Finance Act 2025 replaced domicile-based IHT with a residence-based test. Worldwide assets fall within the scope of UK IHT (at 40%) when an individual has been UK resident in at least 10 of the preceding 20 tax years. HMRC's guidance also confirms a 'tail period' of up to 10 years: a long-term UK resident remains within scope of IHT on worldwide assets for up to 10 years after leaving the UK. See GOV.UK: Inheritance Tax.
Is domicile still relevant for anything after April 2025?
Per HMRC's guidance, for Income Tax and CGT purposes domicile is no longer relevant from 6 April 2025. However, HMRC confirms domicile retains relevance in limited circumstances: IHT on trusts created before April 2025 (where domicile at the time of settlement affects excluded property rules); HMRC enquiries into years before 2025/26 where the remittance basis was claimed; and certain succession and private international law matters. The underlying concept of domicile has not been abolished — only its relevance for ongoing income and capital gains taxation.
What does HMRC say about offshore trust structures from April 2025?
According to HMRC's published guidance, from 6 April 2025 UK-resident settlors who have been UK resident for more than four years are taxed on trust income and gains on the arising basis. The historic 'protected settlements' regime is abolished. HMRC confirms that trustees and beneficiaries in offshore structures with UK-resident connections are subject to complex transitional rules. See HMRC's Residence, Domicile and Remittance Basis Manual (RDRM) for detailed guidance.
What is the TRF 'Designate Now, Remit Later' rule per HMRC?
According to HMRC's manual RDRM73000, the TRF operates by designation on a Self Assessment return — the funds do not need to be physically moved to the UK at the time of making the election. Once designated and the TRF charge paid, those funds become 'TRF capital' under RDRM75100 and may be remitted to the UK at any future date — including after the TRF window closes — with no further UK tax charge.
What is HMRC's deadline to lock in the 12% TRF rate for 2025/26?
Per HMRC's Self Assessment rules, the amendment deadline for a 2025/26 return is 31 January 2028. A designation for the 12% rate must appear on a 2025/26 or 2026/27 Self Assessment return that has been filed or amended by that date. Designations in the 2027/28 return attract the 15% rate. There is no TRF in 2028/29 or later — HMRC's guidance confirms the facility closes permanently after 5 April 2028. See HMRC RDRM73000.
How does HMRC say the TRF works for mixed offshore funds?
According to HMRC's RDRM75100 and RDRM75200, where an offshore account holds a mixture of capital, income and gains, the Finance Act 2025 introduced a new Step A1 under section 809Q ITA 2007: TRF capital is treated as remitted in priority to all other income and capital in the mixed fund. This allows the taxable portion of a mixed account to be designated at 12% and separated from clean capital. HMRC also provides for a TRF capital account to hold designated funds separately — see RDRM75310.
Who qualifies to use the TRF?
Per HMRC's RDRM73000, the TRF is available to former remittance-basis users who are UK resident and have pre-April 2025 foreign income and gains that were subject to the remittance basis but have not yet been remitted to the UK. The TRF also applies to unremitted FIG invested in assets — not only cash. HMRC's guidance also confirms the TRF is available to UK resident settlors or beneficiaries of offshore trust structures where the benefit is matched to pre-April 2025 FIG.
How does HMRC classify cryptocurrency for tax purposes?
According to HMRC's Cryptoassets Manual on GOV.UK, cryptoassets are treated as property for tax purposes — not as currency. This means the Capital Gains Tax rules for property apply to disposals. HMRC's guidance also states that the situs (location) of a cryptoasset follows the beneficial owner's UK tax residence, not the jurisdiction of any exchange or storage device. UK-resident holders are therefore subject to UK CGT on worldwide crypto disposals.
Is swapping one cryptocurrency for another a taxable event according to HMRC?
Yes — per HMRC's Cryptoassets Manual, every crypto-to-crypto swap is treated as a disposal of the first asset at its sterling market value at the date of the transaction. A CGT event occurs at the point of exchange. This applies to all token swaps — including DeFi interactions, liquidity pool entries and NFT mints — not only conversions to pounds sterling.
What are the HMRC published CGT rates on cryptocurrency 2022/23–2026/27?
Per HMRC's published CGT rates on GOV.UK: 2022/23 — 10%/20%; 2023/24 — 10%/20%; 2024/25 disposals before 30 October 2024 — 10%/20%; 2024/25 from 30 October 2024 — 18%/24% (Autumn Budget 2024 increase); 2025/26 — 18%/24%; 2026/27 — 18%/24%. Annual exempt amount: £12,300 (2022/23), £6,000 (2023/24), £3,000 (2024/25 onwards). Source: GOV.UK — CGT rates.
What are HMRC's Section 104 pooling rules for crypto?
According to HMRC's guidance, each type of cryptoasset must be pooled in a single Section 104 pool, with an average cost calculated per unit across all acquisitions. Two override rules apply in sequence: (1) same-day rule — disposals and acquisitions of the same asset on the same day are matched first; (2) 30-day rule — acquisitions within 30 days after a disposal are matched before the pool, preventing 'bed and breakfasting'. HMRC's manual contains worked examples of how the pooling rules apply.
What is CARF and what does HMRC say it means for crypto holders?
The Crypto-Asset Reporting Framework (CARF) is an OECD global standard. According to HMRC's published guidance, UK crypto service providers must report user transaction data to HMRC from 2026. HMRC's guidance confirms that CARF data-sharing operates across 40+ countries — meaning HMRC will receive your transaction history from overseas exchanges where you used UK identification. See GOV.UK crypto guidance for HMRC's reporting requirements.
How does HMRC say staking rewards should be taxed?
Per HMRC's Cryptoassets Manual, staking rewards are generally treated as miscellaneous income — taxable as Income Tax at the sterling value on the date the reward is received. If staking is carried on at a sufficient scale to constitute a trade, the profits may be treated as trading income subject to Income Tax and NICs. The subsequent disposal of staked tokens is also a CGT event, with the acquisition cost being the income value recognised when received.
Can I claim a loss on cryptocurrency according to HMRC?
Per HMRC's published guidance, capital losses on crypto disposals can be offset against other capital gains in the same tax year, or carried forward to future years. To carry forward a loss, HMRC requires it to be reported within four years of the end of the tax year in which it arose — either on a Self Assessment return or by letter. HMRC's guidance states that lost or stolen crypto is not automatically a capital loss — a negligible value claim may be available in certain circumstances.
How does HMRC say NFTs are taxed?
According to HMRC's Cryptoassets Manual, non-fungible tokens (NFTs) are treated as cryptoassets for tax purposes. Selling, gifting or swapping an NFT is a CGT disposal. Creating and selling NFTs as a trade attracts Income Tax and potentially NICs. Each NFT is unique and cannot be pooled with others — it is treated as a distinct asset for CGT cost purposes.
What is the trading allowance according to HMRC?
According to HMRC's published guidance on trading and property allowances, the trading allowance gives individuals £1,000 of gross self-employment income per tax year that is free of Income Tax and NICs (for 2022/23 through to 2026/27). 'Gross' means before deducting any expenses. If gross trading income is £1,000 or less, no Self Assessment registration is required (unless you have another reason to file). Above £1,000 gross, you must register. You may deduct either the £1,000 allowance or actual expenses — not both.
What does HMRC's DAC7 platform reporting mean for sellers?
According to HMRC's published platform reporting guidance, digital platforms including Airbnb, eBay, Etsy, Vinted, Uber, Deliveroo and Fiverr must report seller and service-provider income to HMRC annually under DAC7 rules. First mandatory reports covering 2024 data were submitted in January 2025. This means HMRC can cross-reference its data with what is declared on Self Assessment returns. No new tax was introduced — the same rules that have always applied to trading income continue.
When does Making Tax Digital apply to side hustle income?
According to HMRC's MTD for ITSA guidance on GOV.UK, MTD for Income Tax is mandatory from April 2026 for sole traders and landlords with combined qualifying income over £50,000. The threshold drops to £30,000 from April 2027. Below these thresholds, traditional annual Self Assessment filing continues. MTD requires digital record-keeping and quarterly submissions to HMRC via MTD-compatible software.
Does HMRC treat influencer free products as taxable income?
According to HMRC's published guidance on employment income and trading income, non-cash benefits received in exchange for promotional services — including free products, experiences, travel and services — are treated as taxable income at their sterling market value on the date received. HMRC's 'Help for Hustles' campaign specifically highlights influencers and content creators as a compliance focus area. Free items received with no conditions or expectation of promotion may be treated differently, depending on the specific circumstances. See GOV.UK: Income Tax overview.
What expenses can be deducted from side hustle income per HMRC?
According to HMRC's guidance on allowable expenses for the self-employed, deductible costs must be incurred wholly and exclusively for the purpose of the trade. HMRC identifies common allowable deductions including: platform and transaction fees, materials and stock, business mileage at HMRC's approved rates (45p per mile up to 10,000 miles, 25p thereafter), professional subscriptions, accountancy fees, and a proportion of phone and internet costs for business use. You cannot claim both the trading allowance and actual expenses simultaneously.
What is an HMRC nudge letter and what does HMRC's guidance say to do?
HMRC's 'one to many' letters are sent when HMRC's data — from CRS exchanges, DAC7 platform reports or CARF crypto data — suggests a possible discrepancy. According to HMRC's WDF guidance, where undisclosed offshore income or gains are involved, the Worldwide Disclosure Facility is the required route for disclosure — simply amending a Self Assessment return is not sufficient for offshore matters. HMRC's guidance also confirms that responding before HMRC opens a formal enquiry constitutes an unprompted disclosure, which attracts lower penalties.
How far back can HMRC investigate offshore income?
According to HMRC's published Enquiry Manual, HMRC's standard time limits are 4 years for innocent errors, 6 years for careless errors, and 20 years for deliberate offshore non-disclosure. The 20-year extended period was introduced specifically for offshore matters and covers undisclosed foreign income, offshore bank accounts and non-UK assets. HMRC's guidance confirms the 20-year period has been used in crypto, overseas rental and offshore investment cases.
What are HMRC's published penalties for undisclosed offshore income?
According to HMRC's published offshore penalty guidance, penalties range from 30% to 200% of unpaid tax under the Requirement to Correct regime, depending on: (1) territory category — Category 1 (e.g. USA, EU: lower penalties), Category 2, or Category 3 (non-exchanging territories: highest penalties); (2) whether the failure was innocent, careless, deliberate or deliberate and concealed. HMRC's guidance confirms that voluntary unprompted disclosure substantially reduces penalties — typically to 0–30% for innocent errors in Category 1 territories.
What is the Worldwide Disclosure Facility and why does HMRC require it?
According to HMRC's published WDF guidance on GOV.UK, the WDF is HMRC's required online service for voluntarily disclosing undeclared offshore income, gains and assets. HMRC's guidance states this is the appropriate — not merely suggested — route for offshore disclosures, in contrast to simply amending a Self Assessment return. The WDF is accessed through HMRC's Digital Disclosure Service on GOV.UK.
What is the Common Reporting Standard (CRS) and how does HMRC use it?
The Common Reporting Standard (CRS) is an OECD framework under which over 100 countries automatically exchange financial account information. According to HMRC's published guidance, UK residents with accounts and investments in participating jurisdictions have their balances, income and transaction data reported to HMRC automatically each year. HMRC uses this data to identify discrepancies with declared income on Self Assessment returns. See HMRC's guidance on automatic exchange of information.
I received an HMRC nudge letter about cryptocurrency — what does HMRC's guidance say?
HMRC has issued multiple waves of crypto nudge letters since 2021, using data from UK and overseas exchanges. According to HMRC's WDF and disclosure guidance, if you have undeclared crypto gains, the correct route is to use the Digital Disclosure Service or WDF before HMRC opens a formal enquiry. HMRC's guidance confirms that making an unprompted disclosure results in substantially lower penalties. If gains relate to offshore exchanges, the WDF is the required route. For help calculating your position accurately and responding to HMRC, speak with a qualified crypto tax specialist.
Where can I find HMRC's official guidance on cross-border tax?
Key HMRC sources on GOV.UK: RDR3 (SRT guidance) · RDRM Manual · Cryptoassets Manual (CRYPTO) · WDF guidance · Trading allowance · Tax on foreign income. The UK Tax Hero AI Chat can also help you navigate HMRC's published guidance quickly.
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Important — information only, not tax or financial advice. UK Tax Hero summarises HMRC's published guidance as a free information and expert-matching service. Nothing on this page constitutes personal tax advice, financial advice or legal advice. Every individual's circumstances are different. Figures, rates and rules shown are based on HMRC's published guidance for tax years 2022/23 to 2026/27 and may be subject to change. Always verify information directly on GOV.UK and seek advice from a qualified tax professional before making any decisions. References to HMRC's internal manuals (RDRM, CRYPTO, etc.) are provided for information — they are not a substitute for professional advice on your specific facts. UK Tax Hero is not regulated by HMRC, the FCA or any professional body.