Finance Bill 2017: Non-dom changes effective from 6 April 2017

13 April 2017

Speed read

Finance Bill 2017 has recently been published and includes the latest iteration of the non-dom changes.

High level summary of the changes from 6 April 2017:

  • UK residential property (and related loans) will be brought within the charge of UK IHT, even if held via a non-UK structure.
  • Non-doms who have been UK resident for 15 out of the previous 20 tax years will be treated as deemed domiciled in the UK for all tax purposes and lose access to the remittance basis (capital gains tax rebasing will be available to some).
  • Protections have been brought in for non-UK trusts affected by the deemed domicile rules.
  • All non-doms will have a 2 year opportunity to "cleanse" their mixed fund accounts in preparation for their use.
  • Some provisions included in previous drafts of the legislation were not included in this latest version (the Government have confirmed that these will be deferred to a later Finance Bill).

See our summary paper covering the current changes here.

For more information please contact your usual PwC contact or Dipan Shah on Tel: 020 7804 0685 or email: [email protected]



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