For internationally mobile individuals and their employers, the 2026 Budget did not announce another wholesale rewrite of the rules. That is perhaps welcome after the significant reforms introduced from April 2025, including the four-year foreign income and gains (FIG) regime and the move to a residence-based inheritance tax framework as opposed to the long-standing reliance on domicile. 

There were however, several measures in the small print that matter for people and structures crossing borders. One administrative measure employers with a Globally Mobile workforce will be interested in, is the upcoming introduction of Mandatory Payrolling of Benefits in Kind. There is also a useful easement on the CGT exit charge where a trust becomes temporarily UK resident due to the relocation of a trustee to the UK. Wider changes to tax rates on savings and property income may also affect internationally mobile employees with UK assets or income. 

The Introduction of Mandatory Payrolling of Benefits in Kind 

This legislation will require employers to report and payroll most benefits in kind and taxable expenses through Real Time Information (RTI). For company cars and vans, car and van fuel and medical benefits the changes will take effect from 6 April 2027. All other benefits in kind, with the exception of employment-related loans and employer-provided living accommodation, will take effect from 6 April 2028. Employers with a globally mobile workforce will be relieved to know there is an option to voluntarily exclude qualifying globally mobile employees (GMEs) including short-term business visitors covered by an Appendix 4 agreement from real-time benefit payrolling and continue reporting via traditional P11D/P11D(b) processes. 

Other administrative measures 

HMRC compliance: recruitment of additional compliance officers means employers should expect more HMRC scrutiny particularly in relation to employment taxes and employees with overseas income or assets 

Self-Assessment Payments on account: employers with tax equalised employees may be required to make more frequent payments to HMRC unless they have an Appendix 6 agreement in place. 

Business travel and subsistence rates: scale rates are being modernised, and overseas scale rates are being simplified. This potentially means less expense admin for employees with international travel and employers may need to update their expense policies. 

A useful easement for temporarily UK-resident trusts 

Trust residence can sometimes change as a consequence of a trustee moving between jurisdictions.  

Under the existing rules, a trust that becomes UK resident and later ceases to be UK resident can face a CGT exit charge when it leaves the UK tax net. That can create a disproportionate tax consequence where the change in residence is temporary and driven by an individual trustee’s move rather than a fundamental change in the trust’s long-term arrangements. 

Budget 2026 addresses this point, with effect for exit charges arising on or after 28 October 2026, a trust may become UK resident without triggering the usual CGT exit charge when it subsequently becomes non-UK resident, provided: 

• the trust became UK resident because one or more trustees moved to the UK; and 

• it ceases to be UK resident later in that tax year or in the following tax year. 

The Government’s stated objective is to make it easier for trustees to move to the UK and to support the UK’s position as a destination for globally mobile talent. 

This is a narrow relief rather than a general exemption for trusts moving in and out of the UK. The residence of the trust as a whole and the precise timing of arrival and departure therefore remains important. Trustees contemplating an international move should establish the trust’s residence position before relocating and revisit it if plans change. 

Employer-paid immigration costs: welcome clarity 

There is also a practical change for employers sponsoring workers under the Skilled Worker route. 

The Budget introduces an Income Tax exemption where an employer pays the Immigration Skills Charge or Certificate of Sponsorship fee for an employee or prospective employee. The intention is to prevent the sponsored individual being taxed on these mandatory costs and to align the Income Tax treatment with National Insurance treatment. 

The exemption applies whether or not the individual has started employment when the cost is paid, and whether or not the eventual visa application succeeds. 

Importantly, it is limited to these two charges. Other immigration-related expenses remain subject to the normal tax rules, so employers should not assume that all visa, relocation or immigration expenditure is automatically exempt. Businesses with internationally mobile workforces should therefore continue to distinguish carefully between different costs in their mobility and expenses policies. 

Alongside this income tax measure, the Global Talent visa, High Potential Individual (HPI) and Graduate visas have all been expanded to assist in bringing more talent into the UK with the clear messaging that the UK is “open for business”. 

Higher tax rates on UK savings and property income 

From 6 April 2027, the Budget proposes savings income tax rates of 24%, 44% and 49%. Property income rates are also due to become 24%, 44% and 49% in England, Wales and Northern Ireland, subject to the interaction with devolved powers. 

For globally mobile people, this is relevant even where the move itself is unaffected. UK rental property, UK savings and other continuing UK income streams can remain part of a person’s tax profile after an international move. Residence status, double tax treaty provisions and foreign tax credit relief may all affect the ultimate position, so the headline rate should not be considered in isolation. 

The Budget materials also expressly provide for higher property and savings rates for trustees from April 2027. This may be relevant to international trust structures with UK source income, although the correct treatment will depend on the nature and residence status of the trust and the beneficiaries. 

And finally…a welcome consultation has been announced to consider double tax relief for individuals operating through US LLCs. As this is a common way of doing business or making property or other investments in the US, this will be a relief to many inpats and to US businesses planning an expansion into the UK. 

The wider backdrop: the post non-dom (FIG) regime remains central 

The Budget needs to be read against the major changes already made from 6 April 2025. The remittance basis of taxation was abolished and replaced by the four-year FIG regime for qualifying new residents. Broadly, an individual can qualify during their first four years of UK residence following at least ten consecutive tax years of non-UK residence, with claims available for qualifying foreign income and gains including up to 30% of employment income where there are workdays abroad. This can represent a significant cost saving to employers where there are tax protection or tax equalisation arrangements in place for some or all of their globally mobile workforce. 

Inheritance Tax also moved away from domicile as the principal connecting factor towards a residence-based system. For anyone moving to or from the UK, the interaction between residence, overseas assets, trusts and the timing of a move can therefore be just as important as the measures announced on Budget day itself. 

What should internationally mobile taxpayers and their employers do now? 

The measures do not call for wholesale restructuring, but they do reinforce the value of taking advice before, rather than after a cross-border move. 

Individuals and employers should consider: 

• Mandatory payrolling of benefits: assessing who are the qualified GMEs so they can be opted back into the P11D system for benefits reporting. 

• Trustee moves: if the individual is a trustee, determine whether their relocation could alter the residence of their trust, and if so, what action to take so the new temporary-residence relief can apply, including carefully monitoring the period the trust remains UK resident. 

• Sponsored employees: review which immigration costs the employer pays and ensure payroll and benefits processes distinguish the newly exempt charges from other immigration expenditure. 

• UK income after a move: model the effect of the higher savings and property income rates from April 2027 where UK income will continue after arrival in, or departure from, the UK. For employers this is particularly important where tax equalisation or tax protection arrangements are in place. 

• Existing international planning: revisit advice given including that relating to the FIG and residence-based IHT regimes where personal circumstances, residence plans or trust arrangements have changed. 

• More than one jurisdiction: take coordinated advice where a move creates tax exposure in both the UK and another country; the UK treatment is only one side of the analysis. 

A Budget of targeted changes rather than another reset 

For global mobility, Budget 2026 is less about a new regime and more about limited targeted adjustments to the framework already in place. The temporary CGT protection for trusts is noteworthy because it removes a potential obstacle to moving an employee who is a trustee into the UK, where trustee mobility causes a short-lived change of trust residence.  

The sponsorship-cost exemption should also simplify the position for employers bringing skilled workers to the UK. 

The detail still matters. Cross-border tax outcomes depend heavily on residence, timing, the nature of income and assets and, for trusts, the identity and location of trustees and beneficiaries. Anyone planning a move or responsible for a trust or business affected by one, should review the position early, before the facts become fixed.