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Tax Aware

Issue 21: June 2025

Tax Aware

Editor's note

Nicola Simmons

Following a very eventful period of tax changes, this issue covers a high level summary of the recent non-domiciled tax changes, the recent VAT tribunal decision on crisps, the upcoming inheritance tax changes to Business Property Relief (BPR) and Agricultural Property Relief (APR), the futureproofing benefits of using a personal holding company in preparation for the sale of a UK business, a case update on the fundamental conflict between the right to privacy versus the Automatic Exchange of Information and a summary of US/UK tax considerations for US/UK investors. In this Issue, we have also brought back our popular Tax Aware FAQ, this time answering the commonly asked question of whether a UK leaver should sell or rent their residential properties.

Read the full note

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Non-dom tax changes

The taxation of non-domiciled taxpayers has been significantly overhauled since April. The most significant of those changes are summarised here.

News
View of english countryside fields

Agricultural and Business Property Relief: Proposed 2026 changes

Following the announcements in the Government's October 2024 budget, UK farmers and business owners must start to get to grips with the proposed changes to inheritance tax and the well-established Agricultural Property Relief (APR) and Business Property Relief (BPR) incoming in April 2026.

News
White buildings in London

Tax aware FAQ: I'm leaving the UK - should I sell or let my property?

Non-domiciled homeowners leaving the UK are increasingly asking whether to rent out, or sell, their UK residential properties, following the introduction of the non-dom tax changes on 6 April 2025. There is no 'one-size-fits-all' answer, and there are a number of key factors to consider from a UK tax perspective.

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