What has been delayed?
The non-UK domiciliaries changes that were expected as of 6th April 2017 have been removed from the Finance Act due to the timing of the General Election. Further clarity will be provided in the post-election budget. The changes are likely to be implemented in the April 2018 Finance Act.
What are the key changes that were proposed?
- An individual to be domiciled in the UK for income tax, capital gains tax and inheritance tax after 15 out of 20 years of UK residence;
- A UK-born domiciliary who had acquired a domicile of choice outside of the UK to be deemed UK domiciled on taking up UK residence again;
- Inheritance tax to be charged on UK residential property held through offshore trusts and companies by non-UK domiciliaries.
What should I do?
No planning should be undertaken until the election is over and the new Government indicates their intentions with respect to these proposed changes. In particular, anyone expecting to sell assets after 6th April 2017 to take advantage of the rebasing of assets should defer any sales until the position is clearer.
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.