Non-domiciliaries

Reform of Domicile Rules

As previously announced, with effect from April 2017 non-UK domiciled individuals will be deemed to be UK domiciled for all tax purposes after they have been UK resident for 15 out of the past 20 tax years. Individuals who were born in the UK and who have a UK domicile of origin will be treated as UK domiciled for tax purposes while resident in the UK.

It has now been confirmed that individuals who become deemed-domiciled in April 2017 will be able to treat the base cost of their non-UK assets as the market value of that asset on 6 April 2017. Individuals who expect to become deemed UK domicile under the 15 out of 20 year rule will be subject to transitional provisions with regards to offshore funds.

The reforms will be included in Finance Bill 2017.