AS2016: permanent non dom status removed from April 2017

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The changes to non dom status set out in earlier Budgets will go ahead from April as planned despite a last-minute consultation which could have given some respite to the UK’s community of non domiciled individuals

As previously announced in the Summer Budget 2015 by then Chancellor George Osborne, the government will go ahead with plans to abolish permanent non-domiciled tax status.

From April 2017, non doms will be deemed UK-domiciled for tax purposes if they have been UK resident for 15 of the past 20 years, or if they were born in the UK with a UK domicile of origin.

Non doms who have a non-UK resident trust set up before they become deemed-domiciled in the UK will not be taxed on income and gains arising outside the UK and retained in the trust.

Inheritance tax liability

From April 2017, inheritance tax will be charged on UK residential property when it is held indirectly by a non dom through an offshore structure, such as a company or a trust.

This closes a loophole that the government claims has been used by non doms to avoid paying inheritance tax on their UK residential property.

Inward investment

On a more positive note, the government will change the rules for the Business Investment Relief (BIR) scheme from April 2017 to make it easier for non doms who are taxed on the remittance basis to bring offshore money into the UK for the purpose of investing in UK businesses.

Bearing in mind the decision to vote out of the EU, the government may take a less robust line on future non dom clampdowns as it is keen to attract more capital investment in British businesses from this group. 

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