Non-UK domiciliaries update

The UK Government has announced its decision to introduce into Parliament the Finance (No.2) Bill 2017 as soon as possible after the summer recess. This brings back into contention the changes to taxation for non-UK domiciliaries that we detailed in our bulletin previously sent out in March.

This revised Bill is expected to receive Royal Assent later in the year and reintroduces certain policies that were originally withdrawn from the previous Finance Bill because of the snap general election. Among other things, it contains revised draft legislation on:

  • Corporate interest restrictions
  • Corporation tax loss relief reform
  • Substantial shareholding exemption reform
  • Anti-hybrid rules
  • The new ‘non-dom’ regime
  • Inheritance tax on overseas property representing UK residential property
  • Employment income provided through third parties


What does this mean?

Many of the proposed new clauses are already in force, as the Government has confirmed that all policies set out in the Finance Bill will take effect from April 2017.

The planning points in our previous communication must be looked at sooner rather than later to ensure that your structures are still effective in light of these circumstances.

What is next?

Please speak with a member of our team in conjunction with your tax advisor so that we can work together to ensure the smooth running of your structures under the new rules.



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