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Non-domicile reforms now in force, backdated to 5 April 2017

Finance Bill (No. 2) 2017 received Royal Assent today.

Finance Bill (No. 2) 2017 received Royal Assent on 16 November which means that the proposed non-dom reforms which were temporarily withdrawn before the General Election earlier this year are now in force.  The key reforms are as follows, and apply retrospectively from 6 April 2017:

  • inheritance tax on UK residences held by non-domiciled individuals through offshore structures;

  • new inheritance tax 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 domiciled for all tax purposes once resident in the UK for 15 out of the past 20 tax years.

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

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