Long-term non-doms are deemed domiciled in the UK for all tax purposes if they have been resident for 15 out of the previous 20 tax years, immediately before the relevant tax year. This means that they cannot claim the remittance basis of taxation and become liable to tax on worldwide income and capital gains (the arising basis). Trusts and offshore structures should be reviewed before a non-dom is deemed domiciled as offshore holdings may be restructured into more suitable vehicles such as “protected trusts”.
Under a variety of global transparency initiatives, governments around the world are sharing more information about accounts held in virtually every financial centre. Individuals who are deemed domicile have an obligation to disclose worldwide income and gains.
For advice on:-
- Preparing for deemed domicile status
- Protected Trusts
- Deemed domicile status and inheritance tax
- Double Taxation Treaties
- Losing deemed domicile status