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Entity Setup Alert: ICTS, Non-Resident Capital Gains & ATED Reforms You Can’t Ignore

Budget 2025 will introduce an International Controlled Transactions Schedule, tighten non-resident capital gains rules and ATED relief claims—with many changes effective from 6 April 2026.

By NomadicTax Research Team · 5-8 min read

Reforms coming down the line for entities and non-resident structures

From Budget 2025 and related legislative action, these are key changes for companies, property entities, and non-resident individuals:

MeasureEffective DateWhat to Look Out for
International Controlled Transactions Schedule (ICTS)accounting periods beginning on or after 1 January 2027Multinationals will need to file detailed ICTS reports as part of CT tax returns. Start preparing systems to capture intercompany pricing and transactions. (gov.uk)
Non-Resident Capital Gains & Dividend Tax Credit changesfrom 6 April 2026The tax credit for non-UK residents on UK dividends is being abolished. New rules for non-resident capital gains on property and potentially other assets. Entities holding UK real estate or receiving UK dividends should review structure and expected cash flows. (gov.uk)
Annual Tax on Enveloped Dwellings (ATED) relief claims processfrom date of Royal Assent to Finance Bill 2025-26, and ATED charges rising 1 April 2026Late relief claims window removed; ATED annual charges will reflect CPI rises. Property holding entities must keep close watch on valuations and ensure compliance. (gov.uk)

What entities should do now (actionable tips)

  • Health check your ownership structure: UK vs offshore entities holding UK property will be affected differently, especially for non-resident CGT and ATED.
  • Forecast cash flows: dividend yield and tax credit losses may reduce net income for foreign shareholders.
  • Upgrade accounting systems: ICTS reporting demands detailed transaction-by-transaction disclosures; start capturing required data now.
  • Review ATED relief eligibility: If your entity qualifies, apply before the changes; ensure reports are timely to avoid penalties.
  • Seek professional advice: Many of these changes interact with treaty rules and past investments; cross-border compliance should be reviewed.

Example scenario

An overseas company owns several UK residential properties via a UK SPV.

  • It currently claims ATED relief annually and benefits from the dividend tax credit on rents.
  • From 6 April 2026, dividend tax credit no longer applies for non-UK resident individuals—expect a higher tax burden or loss of relief.
  • For capital gains on property disposals, new rules require non-residents to report and pay CGT where previously they might have claimed exemptions.
  • ICTS obligations may affect intercompany charges or rental management expenses across borders.

Bottom line

If you run or set up an entity owning UK real estate or dealing with cross-border dividends and inter-company dealings, the period around April 2026 is one of significant change. Address structure, accounting, ownership, and reporting to avoid surprises.

Sources

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