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  • Non-doms verily will sigh… Non-dom tax changes Autumn Statement 2016

    24 November 2016

    Andy Wood

    Non doms verily will sigh… Non-dom tax changes Autumn Statement 2016

    The Autumn Statement confirmed that the Government will plough on with the non-dom tax changes. It therefore looks as though non-doms will be spending a chunk of their Christmas holidays mulling over their affairs and with a view to restructuring them ahead of the implementation of the new rules. Certainly a bleak midwinter.

    The silver lining is that there appear to be no new measures announced in the Autumn Statement

    That said, the materials released yesterday do state that non doms who have settled foreign trusts before becoming deemed UK domicile will not be taxed on foreign income and gains arising in the trust.  However, this is at odds with previous announcements that suggest that a trust will lose any protected status if additions are made into the trust or (at least for capital gains purposes) if distributions are made from the trust. This mayy just be a case of sloppy language.

    We have already put together a number of articles considering the impact of the non-dom tax changes which can be found as follows:

    Part one: Setting the scene and what is domicile?

    Part two: The income tax and CGT changes (including rebasing, mixed fund rules and Business Investment Relief)

    Part three: The Inheritance Tax (“IHT”) changes (including revisions to excluded property)

    Part four: Returning non-doms – a tax pariah?

    Part five: The changes in relation to trusts

    Part six: A summary of actions and planning ideas

    The full legislation will be unleashed on 5 December 2016.

    We will be analysing the rules in full in our seminar on Wednesday 7 December in Manchester. Please email for further details.
    If you or your client have any queries regarding the non-dom tax changes then please get in touch.