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Tax Alert

Non-UK domiciliaries and UK residential property

The draft Finance Bill 2017 reforms

Following the announcement of fundamental changes to the future taxation of non-UK domiciliaries (non-doms) in the Summer 2015 Budget and subsequent consultation and discussions with stakeholders, much of the draft legislation has now been released as part of the draft Finance Bill 2017.


The Government announced in the Summer Budget 2015 that it would change the tax treatment of long term UK resident non-doms. UK resident non doms who are either long term residents, or who have a “strong connection” with the UK by virtue of being born in the UK and having a domicile of origin here will become “deemed domiciled” for all tax purposes. These changes will come into effect from 6 April 2017 and will be legislated as part of the 2017 Finance Act.

Draft legislation on most of the reforms has now been released and any significant changes from the position as previously understood are discussed here.

The Government acknowledges that the draft legislation is not complete. The major exclusion is the income tax protections applying to offshore trusts, which will be published at or before the date of the 2017 Finance Bill.

The draft legislation published is open for consultation comments until 1 February 2017.