Residency, Repatriation & Non Doms

Substantial changes to the taxation of non-domiciled UK residents were announced in the 2016 Budget, which are due to come in to effect from April 2017. So called “Non-Doms” who have been UK-resident for more than 15 out of 20 years will no longer be able to access the remittance basis of taxation and will become deemed UK-domiciled.

This change in status could mean that all offshore income and capital gains are likely to fall within the scope of UK taxes. A similar rule is to apply to so called “Returning UK-Doms”. Broadly those who had a UK-domicile at the date of their birth and who emigrated, will be treated as UK-domiciled for tax purposes upon their return to the UK, irrespective of their domicile status under general law. These far-reaching changes not only present challenges for future structuring but can also undermine past restructuring efforts. if you are concerned that your status could change then we would urge you to contact us to conduct a review.

Our Non-Dom Asset Review service involves a comprehensive fact-find process and an in-depth analysis of our ultra high net worth client’s worldwide income, assets and liabilities. Subsequent advice highlights areas of concern in existing arrangements and recommends restructuring efforts to optimise the uk tax position with regards to capital gains tax, income tax and inheritance tax.

Our solutions can include holding overseas ‘excluded’ assets via offshore insurance bonds, offshore discretionary trusts and qualifying non-UK pension schemes, to name a few; all of which we can implement in house. Our solutions are all designed to retain hard earned wealth and permit control over the assets for the long-term.


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