Budget 2016: Chancellor offers rebasing relief for non-doms ahead of critical 5 April 2017 deadline
17 March 2016
Adam Sheffield, senior tax manager at Deloitte, comments on yesterday’s Budget:
“Non-UK domiciled individuals who have been long-term UK resident should already be aware of the significant changes announced in July 2015. From April 2017, those non-domiciled individuals who have been UK resident for at least 15 of the last 20 tax years will no longer be able to claim the remittance basis of taxation in respect of their non-UK income and gains. Instead, they will be subject to UK tax on their worldwide income and gains and their worldwide estate will fall within the UK inheritance tax net.
“It is expected that those affected will be carefully considering their position over the next year in the lead up to April 2017, particularly with regard to the base cost and tax profile of their non-UK assets. The announcement that non-UK assets of those soon to be ‘deemed UK domiciled’ will be rebased at their 5 April 2017 value is a significant measure. This will help define and report the gains which are taxable from 2017.
“The full detail to follow in Finance Bill 2017 will certainly need to be understood and further consultation will be taking place throughout 2016, but this acknowledgement of the practical difficulties in establishing the UK tax profile of non-UK assets is encouraging and it is hoped that this even-handed approach will be reflected across the new regime.”
Notes to editors
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