Non Dom reforms going ahead from April 2017
On 19 August 2016 HMRC finally published further consultation documents on their proposed changes to the taxation of non-UK domiciled individuals (“non-Dom’s”) which will take effect from 6 April 2017. The deadline for responding to the consultation is 20 October 2016.
- Proposed non-Dom changes are likely to be enacted from 6th April 2017, and are not being deferred.
- Individuals living in the UK for more than 15 out of 20 years will be deemed domiciled for all taxes from 6th April 2017.
- Rebasing is available to a limited extent for some individuals, removing retrospective CGT on pre-April 2017 capital gains. This is not intended to be available to trusts.
- Offshore trusts settled by deemed Dom’s are within the scope of “look through” tax treatment. Protection is available in very limited circumstances.
- For one year from 6 April 2017 it will be possible for non-Dom’s to separate out mixed funds, subject to being able to identify their constituent parts. This may involve a lot of analysis work.
- UK residential property will be subject to inheritance tax whether directly or indirectly held. No tax relief is offered to help taxpayers wind up any existing non-UK property holding structures.
If you have any questions or need advice, please contact us