- The government published a call for evidence to review personal tax offshore anti-avoidance legislation, including the transfer of assets abroad and settlements legislation, to “modernise the rules and ensure they are fit for purpose”.
- HMRC published a summary of responses to the call for evidence in July 2025 stating they will “consider how best to engage with relevant experts in shaping and taking forward further consultation in this area”.
- As announced at Autumn Budget 2025, HMRC are establishing a small working group with members from representative bodies to take forward the next phase of policy development.
- Timing: It is anticipated that any transfer of assets abroad or settlements legislation changes will be implemented from the 2027/28 tax year at the earliest.
Resources (click to open)
- Personal Tax Offshore Anti-Avoidance legislation — details of external engagement (HMRC, policy paper, November 2025)
- Open call for evidence: Offshore Anti-Avoidance legislation (HMRC, summary of responses to consultation, July 2025)