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Counting the years

24 May 2016 / Naomi Smith
Issue: 4551 / Categories: Comment & Analysis

The implications of the changes to the inheritance tax rules for UK resident non-domiciles in the Finance Bill 2016.


  • New 15 of 20 years deemed domicile rule.
  • Use of settlor-interested offshore trusts for foreign assets.
  • Problems for individuals caught by the formerly domiciled resident rule.
  • Treatment of UK property held by offshore structures owned by non-domiciles.

The draft legislation in Finance Bill 2016 amends IHTA 1984 s 267 so that individuals will be deemed UK domiciled for inheritance tax purposes where:

  • they are not domiciled in the UK under common law principles; but
  • they have been UK domiciled within the past three years;
  • they are formerly domiciled resident; or
  • they have been UK tax resident for not fewer than 15 of the last 20 years in which the year of assessment falls.

The term...

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