EXPERT LEGAL INSIGHTS / Articles tagged "non-doms"

In his Summer Budget, the UK Chancellor announced major changes to the taxation of UK resident, non-UK domiciled individuals (‘non-doms’) which will have a significant impact on non-doms who have been UK tax resident for more than 15 years (and those approaching 15 years) and non-doms who own UK residential property, however it is held. […]

The 2015 Budget included the following measures of particular interest to private clients:
– deeds of variation – a review of their use will be launched in the Autumn
– disclosure facilities – the UK’s existing disclosure facilities will close early
– restrictions to Entrepreneurs’ Relief

In addition the Budget documents confirm which measures (including those which were announced at the time of the Autumn Statement or earlier) will be introduced before the election and which measures will be held over until the next Parliament.

Changes have been recommended to the Tier 1 (Investor) visa, including:
– increasing the minimum £1 million investment threshold to £2 million;
– removing the ability to borrow the funds that the applicant is required to invest in the UK; and
– introducing a premium route which would offer a successful applicant indefinite leave to remain in the UK after 2 years.

Read this if you, or any of your clients, have a dual employment contract.
The UK Revenue has published draft legislation which will prevent the future use of dual employment contracts in most cases. From 6 April 2014, earnings from the overseas contract under dual contract arrangements, which would previously have been taxable on the remittance basis, will in most cases be taxable on the arising basis.

HMRC considers that using debt to buy assets that are not chargeable to inheritance tax allows scope for “two bites of the cherry”.

Finance Bill 2013 introduces provisions to counter this planning. The provisions restrict the set-off of borrowings if the borrowed money is used to buy assets which qualify for IHT relief. In particular, it has a significant impact on:
• non-UK domiciled individuals (and their trusts) who take out borrowings secured on UK assets to reduce their value for inheritance tax; and
• entrepreneurs using their houses as security for borrowings used in their businesses.

HMRC has proposed changes to the way in which inheritance tax charges on trusts are calculated. If enacted, the proposals will effectively mean an end to ‘pilot trusts’ (see below) and anyone who has established pilot trusts should review their planning. The proposed changes will impact on trustees, settlors and beneficiaries of trusts which are subject to UK inheritance tax, including trusts set up by non-UK domiciled settlors which hold UK assets.

This site uses cookies to help us improve your browsing experience. For further information or to change your cookie settings, view our privacy policy.