Tax position uncertainty for non-domiciled individuals | KPMG Global
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UK: Tax position uncertainty for non-domiciled individuals

Tax position uncertainty for non-domiciled individuals

Finance Act 2017 has led to uncertainty for UK resident non-doms and those owning UK residential property through non-UK companies and partnerships.


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Following over 18 months of uncertainty, non-UK domiciled individuals (non-doms) were expecting their UK tax position from 6 April 2017 in relation to income tax, capital gains tax (CGT) and inheritance tax (IHT) to be as set out in Finance Bill 2017 published on 20 March. However, the calling of the snap General Election resulted in various sections of the Bill being removed before Royal Assent on 27 April. This included the new rules for non-doms and IHT on UK residential property owned through certain non-UK structures. Those affected are now facing yet more uncertainty as to whether the new rules will be brought into effect by the next Government in the form anticipated and, if they are, whether the effective start date will be in 2017, 2018 or potentially some date in between.

Those now facing uncertainty as to their UK tax position include:

  • UK residents who were to become deemed domiciled on 6 April 2017;
  • Non-doms with offshore mixed funds;
  • Individuals and trusts holding UK residential property through non-UK companies;
  • Non-doms who were looking to bring funds to the UK under the Business Investment Relief scheme; and
  • The trustees of certain non-UK trusts.

Those affected will have to wait until the results of the General Election are known and for the new Government to publish the next Finance Bill, or at least release a statement setting out their intentions, before the tax results of certain actions can be known with any certainty. In the meantime, if commercially possible, those impacted should continue to take stock of their current position, ensure their records are in order and wait a little longer. Where that is not practical, steps should be taken to quantify the risks of the different options now available.


For more information, contact a tax professional with the KPMG member firm in the UK:

Greg Limb | +44 20 76945401 |

Mike Walker | +44 20 73118620 |


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