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Coming and going

05 October 2016 / Mark Davies
Issue: 4570 / Categories: Comment & Analysis
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The planning opportunities and pitfalls for non-domiciles arising from the recent consultation document.

KEY POINTS

  • From April 2017 non-doms who have been UK-resident for 15 of the previous 20 tax years will be deemed UK domicile.
  • Deemed domiciles will be able to rebase the cost of foreign assets to the market value on 6 April 2017.
  • Rules for offshore trusts will be amended but there will not be a benefits charge.
  • Fundamental change in inheritance tax on UK residential property.

The government is pressing ahead unwaveringly with its latest set of proposals to reform the UK tax regime for non-domiciles.

George Osborne then chancellor announced the proposed changes in the 2015 summer Budget. On 19 August the Treasury published Reforms to the Taxation of Non-domiciles: further consultation. It contains a lot of new detail and it is clear that non-doms and their advisers have much work to...

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