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Non-domicile reforms – the uncertainty continues

23/06/2017
It was confirmed in this week's Queen's speech that the new Conservative Government intends to introduce three further finance bills in the next two years.  This is to include a Summer Finance Bill

It was confirmed in this week's Queen's speech that the new Conservative Government intends to introduce three further finance bills in the next two years.  This is to include a Summer Finance Bill which will implement policies previously announced.  However it is still not known which of the measures which were dropped from the Finance Bill before the election will be reintroduced, when this will happen or whether the measures will have retrospective effect. 

The reforms which the Government originally intended to implement with effect from 6 April 2017 include:

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

If you would like to discuss the implications of these proposed reforms for you please contact one of the following members of our private client team:

Penny Wotton at penny.wotton@fieldfisher.com

Amanda Gordon-Napier-Tompkinson at Amanda.gordon-napier-tompkinson@fieldfisher.com

Olga Tabenko at olga.tabenko@fieldfisher.com

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