The government has announced that the taxation of non-domiciled persons (“non-doms”) will be reformed from 6th April 2017. Following this non-dom reform in April foreign domiciliaries who have been UK resident for 15 out of the previous 20 tax years will become deemed UK domiciled for all taxes.
Non-doms who are deemed UK domiciled will no longer be able to claim the remittance basis, but there will be protections for offshore trusts established prior to them becoming deemed UK domiciled. In addition there will be opportunity to “re-base” personally held assets where the taxpayer becomes deemed UK domiciled in 2017 and has previously paid the remittance basis charge. The government has also announced an opportunity for taxpayers to re-organise “mixed” funds in the year ended 5th April 2018 to make them more tax efficient going forwards.
Having consulted with interested parties draft legislation is due to be released on 5th December 2016.
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