Capital Gain Tax exit charges — temporarily migrated trusts
Published 28 October 2026
© Crown copyright 2026
This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gov.uk.
Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.
This publication is available at https://www.gov.uk/government/publications/capital-gains-tax-exit-charges-for-temporarily-migrated-trusts/capital-gain-tax-exit-charges-temporarily-migrated-trusts
Who is likely to be affected
Trusts with trustees that move to the United Kingdom (UK) bringing the trust with them.
General description of the measure
This measure allows a trust to become UK resident without triggering the Capital Gains Tax (CGT) ‘exit charge’, which would normally apply when a trust stops being UK resident. The relief is available where a trust becomes UK resident because of one or more trustees moving to the UK, and it ceases to be UK resident later that year or in the following year.
Policy objective
This measure will help trustees move to the UK sooner than otherwise would have been the case, helping the UK become a leading destination for globally mobile talent.
Background to the measure
This measure was announced at Budget 2026.
Detailed proposal
Operative date
This measure will have effect in relation to exit charges on or after 28 October 2026.
Current law
Current law on the residence of a body of trustees for Income Tax and CGT purposes is contained in section 475 of the Income Tax Act 2007 and section 69 of the Taxation of Chargeable Gains Act 1992.
Current law on CGT charges and notification requirements when the trustees of a trust cease to be UK resident is contained in section 80 of, and paragraph 5 of Schedule 5A to, the Taxation of Chargeable Gains Act 1992.
Current law on determining whether an individual is tax resident in the UK for Income Tax and CGT purposes is contained in section 218 of, and Schedule 45 to, the Finance Act 2013 (the statutory residence test).
Proposed revisions
This measure will insert a new section into the Taxation of Chargeable Gains Act 1992.
Summary of impacts
Exchequer impact (£million)
| 2026 to 2027 | 2027 to 2028 | 2028 to 2029 | 2029 to 2030 | 2030 to 2031 | 2031 to 2032 |
|---|---|---|---|---|---|
| Negligible | Negligible | Negligible | Negligible | Negligible | Negligible |
This measure is expected to have a negligible impact on the Exchequer.
Economic impact
This measure is not expected to have any significant macroeconomic impacts.
Impact on individuals, households and families
This measure indirectly impacts individuals and households that hold wealth in trusts outside of the UK. It makes sure that the holdings of these trusts are not taxed by a CGT exit charge should the trust become UK tax resident when a trustee moves to the UK and the trust ceases to be UK resident later that year or in the following tax year.
The identifiable population is highly diverse. It includes ordinary households, as well as high-net-worth and ultra-high-net-worth families, using will or living trusts for immediate children and vulnerable beneficiaries, or holding wealth long-term for future generations.
The use of trusts varies around the world. Only a very small number of offshore trusts will have trustees that move to the UK affecting the trust’s UK tax residence.
This measure is expected to impact individuals’ experience of dealing with HMRC as affected trusts will no longer need to pay a CGT exit charge in these circumstances.
The measure is expected to have no impact on family formation, stability or breakdown.
Equalities impacts
This measure may indirectly impact individuals with trust arrangements regardless of their protected characteristics. HMRC does not hold data that it can use to assess whether there are any disproportionate impacts to protected groups.
Administrative impact on business including civil society organisations
This measure is not expected to impact businesses or civil society organisations with trust arrangements, as the composition of trustees tends to be such that the trust would not change its tax residence when a trustee moves to the UK.
Operational impact (£million) (HMRC or other)
This measure will not require changes to HMRC’s processes or resources.
Other impacts
Other impacts have been considered and none have been identified.
Monitoring and evaluation
The measure will be kept under review through regular communication with affected taxpayer groups.
Further advice
If you have any questions about this change, contact the CGT policy team by email cgtbudget@hmrc.gov.uk.