• Changes for Non-UK Domiciliaries : Spring Budget 2017

Publication: Changes for Non-UK Domiciliaries : Spring Budget 2017

10 March 2017

Please note: the tax proposals described below may not now take effect from the date stated – read more on the tax changes dropped from Finance Bill 2017 as a result of the snap General Election.

Tax changes for non-UK domiciliaries

BDO's analysis of the Government's changes to the taxation of non-UK domiciled individuals contained in the Draft Finance Bill 2017 together with further draft legislation published in January 2017 and announced in Spring Budget 2017:

After a seemingly never ending period of uncertainty we now have the draft Finance Bill 2017 containing changes to the taxation of non-UK domiciled individuals. The Bill will be effective as of 6 April 2017.

Despite pressure to delay the proposals, particularly following Brexit, the UK Government’s project to reform the tax rules for non-UK domiciled individuals (non-doms) will now be implemented.

The update covers the following proposals:

  • The new deemed domicile 15/20 years rule
  • Rebasing for offshore assets for individuals who become deemed UK domiciled on 6 April 2017 under the 15/20 rule
  • A grace period to unravel or ‘cleanse’ offshore mixed fund bank accounts
  • Proposals to charge UK inheritance tax on UK residential property held indirectly through an offshore entity
  • Protections and reforms for offshore trusts
  • Making Business Investment Relief more accessible.

For an analysis of how these reforms impact US citizens living in the UK please see our Tax Changes for Non-UK Domiciliaries – the US Perspective, February 2017.