As clients become more globally mobile in an increasingly transparent world, the specialist advice required becomes even more important.
From individuals considering a move abroad to non-residents turning their attention towards the UK, Lancaster Knox has extensive expertise in advising on the complexities of this ever-changing area of tax. We particularly advise non-UK domiciled individuals becoming ‘deemed domiciled’ under changes introduced from 6 April 2017.
Coming to the UK
The UK’s tax regime for non-UK domiciled individuals continues to be attractive for high net worth individuals and families moving to the UK from overseas. Under the ‘non-dom’ regime, non-UK income and gains may be outside the scope of UK taxation until such time as they are remitted. In addition, non-UK domiciled individuals may be outside the scope of UK Inheritance Tax on their non-UK assets, subject to their affairs being appropriately structured.
For those moving to the UK, putting the right structures in place before their arrival can offer significant benefits. The team at Lancaster Knox specialises in advising non-doms on bank account structuring, holding assets and the ‘remittance basis’ of taxation, from pre-arrival through to becoming UK resident and beyond. Areas on which we can advise include:
The Statutory Residence Test and timing your arrival to the UK
Pre-arrival structuring and bank account segregation
The remittance basis of taxation and tax-efficient remittances to the UK
Liaising with non-UK advisors to ensure a joined-up approach to your move
Long-term UK residents
Substantial changes to the taxation of UK resident but non-UK domiciled individuals were introduced with effect from 6 April 2017. A new ‘deemed domicile’ provision was enacted, meaning non-doms who have been UK resident in at least 15 of the prior 20 tax years will now be treated as being UK domiciled for all UK tax purposes. This means their worldwide income and gains will be within the scope of UK tax, and their worldwide assets within the scope of Inheritance Tax.
For those who are approaching 15 years of UK residence, it is vital that their affairs are reviewed before becoming deemed domiciled so as to ensure they are structured appropriately. Lancaster Knox has extensive experience in this area and can advise on, amongst others, the following areas:
Pre-deemed domicile asset structuring
Excluded Property Trusts to hold non-UK assets
The tax and practical implications of leaving the UK to reset the ‘domicile clock’
The impact of being taxed on worldwide income and gains
Leaving the UK
Individuals may leave the UK for a multitude of reasons, from lifestyle and family relocation to establishing a business overseas. Understanding the implications of becoming non-UK resident, and timing your move appropriately, is vital to ensuring a smooth transition.
Lancaster Knox can advise on the cessation of UK residence, and also has extensive contacts with overseas advisors with whom we can liaise as appropriate. We can also assist with ongoing UK tax compliance requirements, keeping you up to date with your obligations even after your departure.
