On 8 July the UK Chancellor announced three major changes to the taxation of non-UK domiciled individuals which will apply from April 2017:
- Non-UK domiciled individuals resident in the UK for 15 out of the past 20 tax years will be deemed to be domiciled in the UK for income tax, capital gains tax and inheritance tax (IHT) purposes.
- Individuals with a UK domicile of origin who have left the UK and acquired a non-UK domicile of choice, will always be treated as UK domiciled if they return to the UK. The new rule will apply even if they return to the UK before 6 April 2017 and trusts created whilst non-resident will not be treated favourably for UK tax purposes.
- UK residential property owned indirectly by non-UK domiciled individuals, for example through an offshore company, partnership or offshore property trust, will be within the charge to UK IHT
This briefing is also available to download in Russian.