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HMRC IHT guidance on deemed domicile and UK residential property rules

HMRC IHT guidance on deemed domicile and UK

HMRC guidance published covering changes to the IHT deemed domicile rules and new rules extending scope of IHT to UK residential property.


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As expected, HMRC have published high level guidance on the amended deemed domicile rules for Inheritance Tax (IHT) and the new rules extending scope of IHT to all residential properties in the UK that are owned by non-doms, whether the non-doms and any companies that own the properties are resident in the UK or not. These changes also include within the scope of IHT those who lend money or provide security to purchase UK residential property. Such loans will be subject to IHT in the estate of the lender, regardless of the lender’s residence and domicile position. These new rules take effect from 6 April 2017. If you are a non-UK domiciled individual owning UK residential property these new rules will impact you and there are actions you need to consider.

The guidance includes:

  • Inheritance Tax deemed domicile rules – A new short high level summary explaining the deemed domicile rules for IHT purposes; and
  • Enveloped UK dwellings and related finance – New guidance on the rules which take effect from 6 April 2017 and were legislated in the Finance (No.2) Act 2017. This new guidance contains a series of examples which provide a useful high level outline of the operation of the new rules.

For further information about these new rules please speak to Rob Luty, a member of KPMG’s Private Client team or see our article on UK residential property.

For further information please contact:

Rob Luty

Paul Day

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