Autumn Statement 2016: Changes to the Taxation of Non-Doms

The Government previously announced a number of changes that would affect individuals resident but not domiciled in the UK.

Changes have also previously been announced for UK residential property held through offshore structures to bring the properties within the charge to UK inheritance tax.

The Government confirmed these changes will come into effect on 6 April 2017.

The Government also confirmed that non-domiciled individuals who have a non-UK resident trust set up before they become deemed-domiciled in the UK will not be taxed on income and gains arising outside the UK and retained within the trust

Finally, The Government will change the rules for the Business Investment Relief (BIR) scheme from April 2017 to make it easier for non-domiciled individuals who are taxed on the remittance basis to bring offshore money into the UK for the purpose of investing in UK businesses. The Government will continue to consider further improvements to the rules for the scheme to attract more capital investment in British businesses by non-domiciled individuals.

Although the commencement of the new rules has been confirmed. No further detail has been provided at this stage. It is anticipated that the draft legislation to be published on 5 December will include further detail on these changes, otherwise there will be very little time to implement any planning that may be required before the legislation takes effect.