The remittance basis of taxation for non-UK domiciled individuals (non-doms) was replaced with the new Foreign Income and Gains (FIG) regime from April 2025. This new regime is based on tax residence rather than domicile. Under the new rules, nearly all UK-resident individuals must report their foreign income and gains to HMRC, regardless of whether they had previously claimed remittance basis or are claiming relief under the FIG regime.

Former remittance basis users not eligible for the new FIG relief are now taxed on newly arising foreign income and gains in the same way as other UK residents. However, they will still be taxed on any pre-6 April 2025 FIG that is remitted to the UK.

A key feature of the new regime is the 4-year FIG relief. This is available to new UK residents who have not been UK tax resident in any of the 10 preceding tax years. These individuals can opt in to receive full tax relief on their FIG for up to four years. Claims must be made via a self-assessment return, with deadlines falling on 31 January in the second tax year after the relevant claim year. The FUG relief lasts for a maximum of 4 consecutive years starting from when a person first became a UK tax resident. Claims can be made selectively in any of the four years, but any unused years cannot be rolled over.

The types of foreign income which are eligible for relief includes:

• profits of a trade carried on wholly outside the UK
• profits of an overseas property business
• dividends from non-UK resident companies
• interest, such as interest paid on a foreign bank account

An individual’s ability to qualify for the 4-year FIG regime will be determined by whether they are UK resident under the Statutory Residence Test (SRT).

The tax legislation requires the deduction of tax from yearly interest that arises in the UK. This typically refers to interest that is subject to Income Tax or Corporation Tax.

The legislation requires the deduction of tax from yearly interest, if:

• paid by a company, a local authority, a firm in which a company is a partner, or
• paid by any person to another person whose usual ‘place of abode’ is outside the UK.

The tax must be deducted by the person or entity making the payment at the savings rate in force for the tax year in which the payment is made. In practice, the main circumstances where tax is deducted are where a company makes a payment of interest to an individual or other non-corporate person, or where interest is paid by a person (individual, trustee or corporate) to another person whose usual place of abode is outside the UK.

However, some exclusions apply. For example, interest paid by deposit takers, interest paid to a bank or building society, interest paid from UK public revenues or under the former Mortgage Interest Relief At Source (MIRAS) scheme. Companies, local authorities and ‘qualifying firms’ (a firm which includes a company or local authority as a partner) are also exempt from the requirement to deduct tax from interest paid to certain recipients.

It is important to note that statutory interest under the Late Payment of Commercial Debts (Interest) Act 1998, is not classified as yearly interest and does not fall under these rules.

The Enterprise Investment Scheme (EIS) is designed to help smaller, higher-risk trading companies raise finance by offering a range of tax reliefs to investors who purchase new shares in those companies.

This scheme aims to encourage investment in early-stage businesses by providing substantial tax benefits to investors. However, in order to claim EIS tax reliefs, the issuing company must meet a set of strict criteria regarding its size, the amount of money it can raise, and the purpose and timing of the funds raised.

For individual investors, the tax benefits include 30% Income Tax relief on investments, with a maximum annual investment limit of £1 million, or £2 million if at least £1 million is invested in knowledge-intensive companies. The generous tax allowances are intended to offset the higher risk of investing in these smaller companies. It is important for investors to be cautious and only invest money they are prepared to lose, as these companies can be particularly volatile.

The tax advantages of the EIS go beyond just Income Tax relief. Investors can also benefit from Capital Gains Tax (CGT) deferral for the life of their investment and tax relief for any losses incurred on the shares. However, it’s worth noting that Income Tax relief is capped at an amount that reduces the investor’s Income Tax liability to nil for the year, meaning it can’t exceed the individual’s tax due. These tax benefits make the EIS an attractive option for those looking to support high-growth companies while taking advantage of potential tax savings.

Not all casual payments are tax-free; HMRC’s miscellaneous income rules may apply depending on the circumstances.

The special miscellaneous income rules sweep-up provisions that seek to charge tax on certain income. This unusual provision, which is broad in scope, catches income that would not otherwise be charged under specific provisions to Income Tax or Corporation Tax.

A casual payment may be considered taxable miscellaneous income when it is received as a reward for a service that was performed under some form of agreement, arrangement, or common understanding that payment would be made.

This is different from a genuine gift or token of appreciation given voluntarily after a service, where there was no agreement, arrangement or common expectation for such a reward. These gifts are not taxable under the same provisions.

The distinction can be difficult to define. For example, in Brocklesby v Merricks (1934), the court highlighted the importance of an arrangement or entitlement to a share of earnings to make a receipt taxable. As a result, it is essential to review the specific circumstances of each case to determine whether a payment qualifies as taxable income or a non-taxable gift.

If your business operates in a sector covered by the Money Laundering Regulations, you must be monitored by a supervisory authority to ensure compliance. This article outlines who needs to register with HMRC for anti-money laundering (AML) supervision.

Your business must be registered with a supervisory authority if it operates in a sector covered by the Money Laundering Regulations. Some businesses are already supervised through authorisation by bodies like the Financial Conduct Authority (FCA) or professional associations such as the Law Society.

If your business is not already supervised and falls under one of the regulated sectors, you must register with HMRC.

Business Sectors Supervised by HMRC

HMRC is responsible for supervising businesses in the following sectors (where not already regulated by the FCA or a professional body):

• Money Service Businesses not regulated by the FCA
• High Value Dealers handling cash payments of €10,000 or more (in a single transaction or linked transactions)
• Trust or Company Service Providers not supervised by the FCA or a professional body
• Accountancy Service Providers not supervised by a professional body
• Estate Agency Businesses
• Bill Payment Service Providers not regulated by the FCA
• Telecommunications, digital, and IT payment service providers not regulated by the FCA
• Art Market Participants involved in buying or selling works of art valued at €10,000 or more (including linked transactions)
• Letting Agency Businesses managing property or land with a monthly rental value equivalent to €10,000 or more

If your business conducts these activities by way of business and is not already supervised, you must register with HMRC.

Money Service Businesses and Trust or Company Service Providers are not allowed to trade until their AML registration with HMRC is confirmed. Other businesses may continue operating while their registration is being processed.

Trading while not registered is a criminal offence and may result in a penalty or prosecution.