Skip to main content

Non-domicile reforms are to proceed, backdated to 5 April 2017

Following the temporary withdrawal before the election of the proposed non-dom reforms

Following the temporary withdrawal before the general election of the proposed non-dom reforms, the Government has now published Finance Bill (No. 2) 2017 which reintroduces the following reforms (with only minor amendments) which are to take effect retrospectively from 6 April 2017:

  • inheritance tax on UK residences held by non-domiciled individuals through offshore structures;
  • IHT charges for lenders and borrowers;¬† and
  • changes to the taxation of individuals who are not domiciled in the UK including a new provision to deem a non-domiciled individual to be UK resident for all tax purposes once resident in the UK for 15 out of the past 20 tax years.

These provisions will come into force when the Finance Bill (No. 2) 2017 receives Royal Assent.  We are told that this will occur "in the autumn".

For more information please contact one of the following members of our private client team:

Penny Wotton at

Amanda Gordon-Napier-Tompkinson at

Olga Tabenko at

Sign up to our email digest

Click to subscribe or manage your email preferences.