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Non-UK domiciled persons

The UK government has announced proposed changes to the tax treatment of individuals who are resident but not domiciled in the UK. The detailed proposals will be published soon but it appears that any such taxpayer who has been resident in the UK for at least seven years will have to pay an annual levy of £30,000 to maintain non UK domiciled status for income and capital gains tax purposes. More importantly, the government is likely to introduce provisions to assess to UK tax gains or income of non UK trusts where these are associated with UK resident non domiciled persons.

There are also indications that the current regime which allows unremitted overseas income to be converted to capital will be brought to an end.

Non domiciled persons should review their affairs before 6 April 2008 after the detailed proposals are published with a view to reorganising their affairs to minimise or avoid the effect of these changes.

28 November 2007

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