Major reforms to the taxation of non-doms came into effect on 6 April 2017 and the government has recently issued guidance on those changes to assist with interpretation. Further measures concerning offshore trusts are currently being legislated and will come into effect on 6 April 2018. These include the removal of the  ability to "wash out" capital gains from a trust by making payments to non-residents, the introduction of a close family member rule and anti-recycling rules for both income tax and CGT purposes, together with the introduction of a benefits charge under the income tax settlements legislation.

Similarly, offshore trustees with UK-resident and deemed domiciled settlors should seek advice regarding inter-trust loans before 6 April 2018, to avoid the trusts becoming accidentally tainted so that the settlor becomes liable for tax on trust income and gains as they arise.