The Government restated its commitment to reform the tax status of non-domiciled individuals. It confirmed its plans to legislate in the 2017 Finance Bill as follows:
- all non-UK domiciled individuals will be deemed UK domiciled for all tax purposes after they have been UK resident for 15 of the previous 20 tax years; and
- individuals who were born in the UK and who have a UK domicile of origin will revert to their UK domiciled status for tax purposes whilst resident in the UK.
For those who become deemed-domiciled in April 2017, the Budget indicates that such individuals can treat the costbase of their non-UK based assets as being the market value of that asset on 6 April 2017. Individuals who expect to become deemed UK domiciled under the 15 out of 20 year rule will be subject to transitional provision with regards to offshore funds to provide certainty on how amounts remitted to the UK will be taxed.