• Until now, the UK has been one of the most welcoming jurisdictions in Europe where non-UK-domiciled individuals could live.
  • Today, Chancellor George Osborne announced in his Summer Budget that from April 2017 the rules relating to non-UK domiciles will be curtailed further, so as to make long-term stay in the UK undesirable.
  • The Chancellor announced the implementation of the following changes, from April 2017:
    • If you have lived in the UK for more than 15 of the last 20 tax years, you will be deemed UK-domiciled for UK tax purposes, and therefore taxable on your worldwide income and gains.
    • If you were born in the UK to parents who are UK-domiciled, you will no longer be able to claim non-domicile status if you leave but then return and take up residency in the UK.
  • The Government will also introduce new rules to ensure that UK inheritance tax is paid on UK residential property, even when the property is held indirectly through an offshore company or similar structure.
  • Whilst full details of the new rules are not currently available, we will be happy to discuss with you any issues you may face going forward, and explore restructuring opportunities available to reduce your exposure to UK tax.