Key UK Measures from Budget 2025 Affecting Non-Residents
Taken from HM Treasury’s Budget 2025 legislation (Finance Bill 2025-26).(gov.uk) Sudden shifts include:
- Cryptoasset Reporting Framework (CARF): UK cryptoasset service providers will be required to report on their UK-resident customers.(gov.uk)
- International Controlled Transactions Schedule (ICTS): Multinationals must file ICTS, effective for accounting periods beginning 1 January 2027.(gov.uk)
- Corporate Interest Restriction simplification: administrative changes take effect for periods ending on or after 31 March 2026.(gov.uk)
- Non-resident Capital Gains & ATED Reliefs: The definition of a “property rich entity” will be amended, and ATED late or out-of-time reliefs expanded effective 1 April 2026 (companies) and 6 April 2026 (individuals).(gov.uk)
- Dividend Tax Credit Abolished for Non-UK Residents: Notional credits on dividends from UK companies will no longer apply from 6 April 2026.(gov.uk)
- Construction Industry Scheme (CIS) Fraud Provisions: HMRC gets stronger fraud powers; GPS status can be removed immediately, penalties up to 30%, effective from 6 April 2026.(gov.uk)
Actionable Insights for Non-Residents & Businesses
- Review property ownership: If entities are property rich, ATED definitions change—planning structures should be assessed prior to the April 2026 deadlines.
- Dividend strategies: If you receive UK company dividends, understand that non-residents can no longer use dividend tax credits after 6 April 2026.
- Crypto services or users: UK users of cryptoasset platforms will see more visibility; service providers need compliance systems for CARF.
- Multinationals: For companies with UK footprint, the new ICTS adds a reporting requirement beginning financial years 2027; initiate consultation feedback and prepare transfer pricing documentation.
Compliance & Timing Considerations
- Legislation becomes effective either “from the date of Royal Assent” or specific dates in April 2026, so check whether your tax year is affected.
- Watch for drafting of regulations, especially for schemes like ICTS—consultations in spring 2026 will flesh out details.(gov.uk)
- Maintain records showing compliance with the updated definitions and reporting deadlines.
Examples
- A non-UK resident holding UK company shares who receives dividends after 6 April 2026 can no longer depend on the old credit; effective tax liabilities may increase.
- A business with transactions through a “property rich entity” should check the new definition by 1 April 2026 to assess ATED liability.