Digital Nomad
Upcoming HMRC Consultations: What International & Mobile Individuals Should Watch
UK proposals are being developed to clarify tax treatment for US LLC members, reverse hybrids, and non-resident directors—global mobile individuals should prepare for changes impacting their tax exposure.
By NomadicTax Research Team • 5-8 min read • July 22, 2026
## What’s Being Proposed
HMRC has recently launched several **consultations & calls for evidence** targeting the tax treatment of globally mobile individuals. Key proposals include:
- Updating taxation of **UK resident individual members of US Limited Liability Companies** (LLCs) and other reverse hybrids to remove double taxation where investors suffered effective tax rates above 75%. ([gov.uk](https://www.gov.uk/government/publications/summary-of-tax-update-2026-simplification-modernisation-and-fairness/tax-update-2026-simplification-modernisation-and-fairness-summary?utm_source=openai))
- Clarifying **National Insurance contributions (NICs) easements** for non-resident directors attending some board meetings in the UK but based abroad (in countries without social security agreement). ([gov.uk](https://www.gov.uk/government/publications/summary-of-tax-update-2026-simplification-modernisation-and-fairness/tax-update-2026-simplification-modernisation-and-fairness-summary?utm_source=openai))
## Who Will Be Affected
- Individuals with cross-border business structures or investments involving US LLCs and similar entities.
- Non-resident directors serving in UK companies but residing overseas.
- Employers engaging mobile individuals to perform work in hybrid or intermittent UK presence patterns.
## What to Do Now
1. **Review entity structure**: assess whether your overseas holding or LLC-type investment creates exposure to reverse hybrid rules and unintended double taxation.
2. **Estimate potential tax rates** based on current structure: some may exceed 75% before reforms.
3. **Hold off irreversible contracts or decisions**, if possible, until consultation ends and final regulations are published.
4. **Engage with advisors** on future planning – consider trusts, residency, Permanent Establishment, or UK tax treaties.
## Future Timelines & Expectations
- These are **consultations or calls for evidence**, not yet legislated. Details could change substantially before enactment. ([gov.uk](https://www.gov.uk/government/collections/taxupdate-2026-simplification-modernisation-and-fairness?utm_source=openai))
- Stakeholder feedback likely to influence definitions, scope, thresholds.
- Watch Finance Bill 2026-27 for eventual legislation incorporating these changes.
## Practical Example
Jane is a UK resident investing through a US LLC. Under current rules she may face double withholding or surprise tax liabilities. If reforms proceed in the way HMRC suggests, she may gain **relief or reclassification** that avoids the higher rates. But until reforms are final, maintain conservative estimates and plan for possible transitional arrangements.