There have been a raft of changes to the taxation of non-domiciled individuals, and the area has grown significantly more complex since comments in the Summer 2015 Budget. It is important that non-domiciled individuals obtain professional advice to ensure they do not fall foul of the complex legislation in this area and carefully plan their affairs to maximise this advantageous status.
There will be a new deemed-domicile rule (the ‘15 year’ rule), where long-term UK residents may be unable to benefit from the remittance basis of taxation and will become deemed UK domiciled for all relevant heads of taxation – Inheritance Tax (IHT), Capital Gains Tax (CGT), and Income Tax (IT).
The rules around the old ‘estate duty treaty’ reliefs relating to deemed-domicile for IHT purposes may also be changed, which could affect non-domiciled clients with Indian, Pakistani, French or Italian domiciles of origin.
We are able to offer expert advice in the following areas:
- The remittance basis of taxation and tax-efficient remittance structuring
- Offshore mixed funds and clean capital analysis
- Remittance basis charge planning
- IHT planning including excluded property trusts
- Overseas Workday Relief (OWR) claims
- Completing tax returns for non-domiciled individuals
- Pre-arrival planning
- Double tax agreements
- Domicile reviews
- Statutory Residence Test (‘SRT’) and residence planning.
- The taxation of offshore life policies
- New rules on IHT exposure for UK residential property held via offshore structures.
Domicile – a deep dive into case law and how it may apply to you
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