The government plans to apply inheritance tax (IHT) to
residential properties in the UK where they are held within an
The charge will apply both to individuals who are domiciled outside
the UK, and to trusts with settlors or beneficiaries who are
non-domiciled, and will come into effect from 6 April 2017. It will
be legislated as part of the 2017 Finance Act.
Deemed UK domicile for long-term residents
The consultation period confirmed that the IHT deemed-domicile
provisions would change to be brought into line with the proposed
changes to income tax and capital gains tax. This would have the
effect of treating an individual as deemed-domiciled for IHT, when
they have been resident in the UK for at least 15 of the past 20
As with the income and capital gains tax provisions, for those
who leave the UK before 6 April 2017 but are nevertheless deemed
domiciled under the 15/20 rule on 6 April 2017, the present rules
Born in the UK with a UK domicile of origin
The UK Government believes it is only reasonable to treat those
individuals born in the UK and with a domicile of origin as being
domiciled in the UK for tax purposes, when they are resident in the
Tax planning for non-domiciled individuals - and how we can
The use of offshore trusts by non-domiciled individuals appears
to be of increasing importance for tax planning purposes, and for
individuals that will be treated as deemed UK domicile on 6 April
Creating an offshore trust before this date is something that
should be considered with a tax advisor as a matter of
TMF Group's specialist private client teams are able to work
with you and your advisors on the structure they recommend will be
best suited to fulfill your needs, for effective family and
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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Under current law, where a business subject to corporation tax or income tax reallocates an existing asset into its trading stock, the basic rule is that there is a deemed market value disposal of the asset...
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