Tax Aware Issue 21: June 2025 Editor's note 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 News 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 VAT: Zero-rating crumbled - Walkers' snack fails the crisp test Last month, Walkers Snack Foods Ltd failed to convince the Upper Tribunal that its Sensations Poppadoms snack should be zero-rated for VAT. News 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 From exit to encore: Future-proofing with a personal holding company 2025 presents an opportunity for forward-thinking founders and investors to evaluate how their wealth is structured. A personal holding company (PHC) can offer a solution. News FATCA: Belgian decision shows the direction of travel We now have not one, but two decisions from the Belgian data protection authority on the incompatibility of FATCA with the GDPR. News Navigating the transatlantic tax maze: UK investment into the US The UK tax rules are notoriously complex, meanwhile, the US Internal Revenue Code presents additional challenges. Tax-efficient US-UK investing requires alignment in tax treatment to ensure tax in one country is creditable against tax in the other. News 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. Subscribe Never miss a publication by signing up to our mailing list Subscribe Tax Aware: Subscribe Tax Aware Issues Next Previous Issue 22 Sep 2025 Issue 21 Jun 2025 Issue 20 Dec 2023 Issue 19 May 2023 Issue 18 Jan 2023 Issue 17 Sep 2022 Issue 16 Apr 2022 Issue 15 Jan 2022 Issue 14 Jun 2021 Issue 13 Feb 2021 Issue 12 Sep 2020 Issue 11 Apr 2020 Issue 10 Nov 2019 Issue 9 Jul 2019 Issue 8 Feb 2019 Issue 7 Oct 2018 Issue 6 Jul 2018 Issue 5 Apr 2018 Issue 4 Jan 2018 Issue 3 Oct 2017 Share
News 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 VAT: Zero-rating crumbled - Walkers' snack fails the crisp test Last month, Walkers Snack Foods Ltd failed to convince the Upper Tribunal that its Sensations Poppadoms snack should be zero-rated for VAT.
News 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 From exit to encore: Future-proofing with a personal holding company 2025 presents an opportunity for forward-thinking founders and investors to evaluate how their wealth is structured. A personal holding company (PHC) can offer a solution.
News FATCA: Belgian decision shows the direction of travel We now have not one, but two decisions from the Belgian data protection authority on the incompatibility of FATCA with the GDPR.
News Navigating the transatlantic tax maze: UK investment into the US The UK tax rules are notoriously complex, meanwhile, the US Internal Revenue Code presents additional challenges. Tax-efficient US-UK investing requires alignment in tax treatment to ensure tax in one country is creditable against tax in the other.
News 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.