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Non Dom reforms going ahead from April 2017
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.
In Summary
- 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