HMRC has published draft legislation, to be included in Finance Bill 2016, regarding the rules on deemed domicile. The new rules will apply to persons born in the UK, with a UK domicile of origin who are resident in the UK, or where a non-UK domiciled person has been resident for 15 out of the previous 20 tax years. The changes are due to have effect from 6 April 2017.

Concerns have been expressed that this legislation will be enacted before the scope of any exceptions, in particular, in relation to offshore trusts, have become clear, leading to a period of uncertainty for those affected.

The draft legislation is available to view here.