Results of the UK government consultation on reforms to the taxation of non-domiciles


Filed Under: Private Client

HM Revenue & Customs ("HMRC") has today finally published their response to the non-domicile consultation after almost nine months, announcing a further consultation on the overall reforms which were first announced over a year ago.

The new consultation will run until 20 October 2016, but it would appear that the announcements today will largely be the final form.
Despite speculation following the EU referendum that the reforms might be dropped or delayed, the consultation document confirms that the previously announced reforms will go ahead from 6 April 2017.
Today's consultation response finally offers more details on the long-awaited changes to the inheritance tax ("IHT") position in relation to UK residential property and the taxation of offshore trusts.  The IHT provisions appear to be broadly in line with what was expected but, disappointingly, there is no de-enveloping relief to remove properties from companies.  Whilst the offshore trust changes were expected to offer a new form of protection to non-domiciled individuals, the proposals are not as favourable as first hoped.  There are however some welcome and generous new rules in relation to an April 2017 rebasing and an opportunity to untangle mixed funds.
Please click on one of the following links for further details of today's announcements and their implications:
Further consultation for non-doms finally published
New offshore trust rules for deemed domiciled individuals
Inheritance tax on UK residential property

For more information, please contact your usual Blick rothenberg adviser or Caroline Le Jeune at