Kessler on Private Client Taxation 2025 - 2026 24th ed Online Access

Previously known as The Taxation of Non- Residents and Foreign Domiciliaries, the author James Kessler KC says: the new title of this work reflects the abolition of domicile, and the approach of this book that territorial rules such as residence must be addressed as part of a general discussion of private client tax; in taxation, as in life, everything is connected.

From the author James Kessler K.C:
2025 is a year that will be remembered in tax history. It announced a set of reforms:

• For IHT
• Long-term residence replaces domicile
• Excluded property trust status depends the settlor’s LTR from time to time
• For IT/CGT
• FIG relief (a short term relief for foreign income/gains) replaces the remittance basis
• Transitional rules include the Temporary Remittance Facility, 2025 rebasing, and a new definition of remittance (for historic unremitted income)

One might summarise this package as the abolition of domicile, though as usual, the short label does not fully describe the details of the reforms.

This is the most important change in UK taxation since the introduction of CGT/CT in 1965, VAT in 1973, and CTT in 1974.

The approach of this work is that territorial rules such as residence and (until 2025) domicile are best addressed as part of a general discussion of private client tax; in taxation, as in life, everything is connected.

The new title of this work from The Taxation of Non- Residents and Foreign Domiciliaries to Kessler on Private Taxation reflects this change and this approach.

For the 2025/26 year and the next few years the volume will be greater than before as it will need to contain much of the old law (which will continue to be relevant indefinitely to income and gains arising in this and previous tax years) as well as the substantial amount of new law.

The book is changing its name from the hugely popular The Taxation of Non- Residents and Foreign Domiciliaries to reflect more closely its contents, but will be the same book which will cover additionally all the many changes being made by Finance Act 2025 as well as all the historic law relevant to income and gains arising prior to 2024/25 which are remitted after the year in which they arise.

The new online edition will be published on 6 April, though some of the active updating may go online slightly later. The hardcopy edition is expected to publish by August 2025.

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