The Treasury has launched a consulation on reforms to the taxation of non-domiciles.
This consultation document sets out the detail of the proposals which restrict certain individuals from claiming non-dom status for tax purposes. A ‘deemed domicile rule’ is proposed so that long-term residents of the UK can no longer claim to be not domiciled for tax purposes. This would abolish the permanency of non-dom status. The new rules are also designed to ensure that individuals who are born in the UK and who are UK-domiciled at birth will not be able to claim that they are not domiciled for tax purposes while they are living in the UK.
This consultation seeks views on how legislation should best be introduced in Finance Bill 2016 to achieve these aims. It seeks views on how the government can introduce these reforms in the most effective way without any unfair or unintended outcomes. Responses are invited from any interested parties, including individuals, advisers and representative and professional bodies.
The government has also announced that it will legislate so that inheritance tax is charged on all UK residential property, including property held indirectly by non-doms through a structure such as an offshore company or a trust. This change is intended for the 2017 Finance Bill and a separate consultation will be published to seek views on the detail of this proposal.
The consultation closes on 11 November 2015.