How have UK exit tax rules evolved since 2018 for expats?

1. Why 2018–2020 set the baseline — corporate exit rules and ATAD teeth

Between 2018 and 2020 the UK strengthened rules aimed at preventing profit relocation and tax base erosion, notably by implementing the EU Anti‑Tax Avoidance Directive (ATAD) which reshaped corporate exit charges and introduced market‑value rules and deferral payment plans for chargeable transfers of residence or assets out of the UK. These measures targeted companies and controlled structures rather than individual emigrants, and they established mechanisms for taxing unrealised gains on relocation while permitting payment arrangements in many cases. The government guidance framed these as anti‑avoidance fixes to close loopholes exposed during the previous decade of tax planning, and practitioners advised trustees and corporate groups to reassess group reorganisations and migrations ^[2].

2. The non‑dom dismantling — FIG, remittance basis removal and transitional relief

The largest individual taxpayer change culminated in April 2025 with the abolition of the classical non‑dom/remittance basis and the introduction of the Foreign Income and Gains (FIG) regime, replacing remittance‑based taxation with a residence‑focused approach and offering a limited four‑year 100% relief for new arrivals. Existing non‑doms faced a phased transition with explicit expectations to bring previously offshore-sheltered wealth into the UK tax net or rely on special transitional arrangements such as Temporary Repatriation Facilities. The Treasury presented these reforms as simplification and fairness measures, while commentators highlighted the end of a long‑standing compliance regime that had shaped UK inward mobility and wealth planning for decades ^{[1] [4]}.

3. What individuals actually lost — reliefs, allowances and planning levers

For individuals, the net effect has been concrete losses of planning flexibility: access to the remittance basis, certain tax‑relieved wrappers, business asset disposal relief sequencing, and in some cases the practical utility of the personal allowance and residence‑tied reliefs were curtailed or re‑scoped. Advisors warned that leaving the UK now requires earlier, more focused exit planning because the timing of departure, asset crystallisations, and interactions with revised Capital Gains and Inheritance Tax rules can materially change liabilities. Some publications also flagged new proposed levies or capital gains triggers for long-term residents ceasing residency, reflecting an appetite in parts of policy debate for formal exit-style charges on individuals ^{[5] [6]}.

4. Corporate migration still taxed — practical mechanics and deferrals

Companies and business owners contemplating migration find that exit charges remain an active enforcement area, with market‑value triggers for chargeable assets and mechanisms allowing deferred payment where liabilities arise from cross‑border changes. The ATAD-era rules gave HMRC clearer statutory bases for levying charges and facilitated the use of staged payment plans; practitioners report routine use of these options to manage cashflow when group entities relocate or when trading activities move jurisdictions. These corporate provisions interact with individual entrepreneur reliefs and disposal reliefs, complicating business sales around the point of emigration and increasing the need for coordinated corporate‑and‑personal tax planning ^{[2] [5]}.

5. The range of views — reform arguments, revenue targets and planning industry reactions

Supporters of reform pointed to fairness and revenue—Treasury estimates and government commentary argued that the FIG changes would raise substantial sums over five years by eliminating perceived loopholes and simplifying the base. Critics and many advisers warned of competitive downsides: the removal of non‑dom advantages could deter high‑net‑worth migration and complicate cross‑border business decisions, while call‑outs for an explicit individual exit tax surfaced in opinion pieces. The policy discourse thus sits between a government emphasis on equity and fiscal consolidation and industry concerns about mobility, administrative complexity, and unintended behavioural responses ^{[4] [6]}.

6. Practical takeaways — what expats and advisers should watch now

For anyone planning to leave or arrive in the UK, the actionable priorities are timing, documentation of residency changes, review of remittances and offshore structures, and coordination between personal and corporate exits. Transitional and relief windows introduced in 2025 provide some breathing room, but evidence from guidance and practitioner commentary indicates that post‑2025 liabilities are more likely and less easily mitigated than before 2018. Taxpayers should therefore obtain jurisdiction‑specific advice early and model scenarios under the FIG and revised CGT/IHT positions to avoid surprises when residency status changes ^{[7] [8]}.