Policy paper

Temporary non-residence rules — post departure trade profits

This tax information and impact note is about changes to the temporary non-residence anti-avoidance legislation to make sure it remains effective against avoidance.

• From: HM Revenue & Customs
• Published: 26 November 2025

Documents

Post departure trade profits

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Draft legislation

PDF, 252 KB, 19 pages

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Draft legislation (accessible version)

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Details

The post departure trade profits provisions will be removed so that all dividends or distributions received from close companies, whilst temporarily non-resident, will be chargeable to UK Income Tax.

This measure also introduces additional legislation to stop individuals avoiding tax by using offshore structures and arrangements.

Published 26 November 2025