Changes to the taxation of non-domiciliaries post 6 April 2017

As announced in Summer Budget 2015 there will be a significant change to the tax treatment of non-UK domiciliaries and their offshore structures.
There are two main changes which are set out below:

  • A new ‘deemed domiciled’ rule for non-domiciled individuals who have been tax resident in the UK for 15 out of the last 20 years.
  • Making offshore structures holding UK residential property ‘look through’ for UK inheritance tax and thus bringing them into the UK inheritance tax net.

We have prepared a brief overview of the above changes and the impact they will have post 5 April 2017.

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Please note this overview has been prepared based on the current draft legislation. It has been confirmed that some of the legislation will be re-drafted due to inconsistencies, although we understand the main principles will remain the same. The late delivery of the draft legislation means that individuals have very little time to plan their affairs; with that they also don’t have absolute certainty over the outcome.


However, there is still time to take action pre-5 April 2017 ahead of the new rules coming in. Please contact us if you would like to discuss the impact of the new rules and how these apply to you or your clients.




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