UK RESIDENCY & DOMICILE

The 2016 UK Budget announced substantial changes to the taxation of non-domiciled UK residents.

The changes announced in the 2016 UK Budget are currently due to come into effect from April 2017. These changes affect “Non-Doms” who have been UK-resident for more than 15 out of 20 years and will no longer be able to access the remittance basis of taxation. They will become deemed UK-domiciled, which means that all offshore income and capital gains are likely to fall within the scope of and be subject to UK taxes.

A similar rule is to apply to “Returning UK-Doms”, who had a UK-domicile at the date of their birth and have emigrated. They will be treated as UK-domiciled for tax purposes upon their return to the UK, irrespective of their domicile status under general law.

These far-reaching changes not only present challenges for future structuring but can also undermine past restructuring efforts. This is a complex area, in which expert advice is essential to ensure legal and tax compliance.

Our Non-Dom Asset Review service involves a comprehensive fact-find process and an in-depth analysis of our client’s worldwide income, assets and liabilities. Subsequent advice will highlight areas of concern in existing arrangements and present recommendations on appropriate restructuring to optimise the UK tax position (capital gains tax, income tax and inheritance tax).

Our solutions can include holding overseas ‘excluded’ assets via offshore insurance bonds, offshore discretionary trusts and qualifying non-UK pension schemes, to name a few. Our solutions are all designed to protect wealth and allow control over assets for the long-term.