16 December 2016
If you have a foreign domicile – particularly if you are already resident in the UK but in one respect even if you have never even set foot in this country – you need to be aware of and plan for a series of changes that are due to come into effect from 6 April 2017.
Draft legislation has now been published with the proposals previously set out in consultation documents subject to some amendment. There are three principal changes:
- Non-doms resident in the UK on or after 6 April 2017 will be treated as UK domiciled if they have been resident in the UK in 15 of the previous 20 tax years.
- Those who were born in the UK with a UK domicile of origin will be treated as UK domiciled if resident in the UK, regardless of whether they have acquired a foreign domicile under general law.
- UK residential property owned via offshore structures will be brought fully within the charge to Inheritance Tax.
There are various reliefs and planning opportunities available and those likely to be affected should take advice at the earliest opportunity.
You can read our more detailed summary of the changes, but this is not a substitute for detailed advice that reflects your personal circumstances which we recommend you seek before taking any action.