An individual owns a UK company, and goes abroad and becomes non-UK resident. HMRC Help Sheet 300 (HS300) makes it clear that they can receive dividends from their UK company free of any UK income tax under the 'disregarded income' rules. However, if the company is a 'close company', there are restrictions. HMRC’s Residence and FIG Regime Manual at RFIG21600 states that dividends paid abroad from trade profits earned by the close company before the individual went abroad are subject to UK income tax if the individual is temporarily non-resident when receiving the dividends; that is, the individual is not non-UK resident for five full consecutive tax years during the period of non-UK residence. But if the individual is non-UK resident for five full consecutive tax years, then during the period of non-UK residence, they are not temporarilynon-resident, and so the dividends are free of UK income tax under the 'disregarded income' rules. At any rate, if the trade profits are earned by the company after the individual went abroad, the 'five full consecutive tax years' rule is not required. Does this still apply? 

Arthur replies: 

In Autumn Budget 2025, it was announced (in a document titled 'Post-departure trade profits') that from 6 April 2026, this 'permit' will not apply. Therefore, to receive dividends from a UK close company free of UK income tax, a non-UK resident will have to be non-UK resident for five full consecutive tax years during the period of non-UK residence, whenever the trade profits are earned by the company.