The new rules bring an end to the permanency of non-dom status
and will mean that those who have chosen to make the UK their
long-term residence will pay tax on the same basis as UK domiciles.
The rules do, however, allow for some flexibility to continue to
reflect the fact that some non-doms are internationally mobile.
Maximise Time Spent in UK
The proposed rules make provision for individuals who have lived
in the UK for 15 consecutive tax years and then leave the UK for 6
or more consecutive tax years, meaning that they could return to UK
and claim non-dom status again for another 15 years (assuming they
still had a foreign domicile status under general law).
The government has stated that introducing the deeming rule in
this way will allow those non-doms who are internationally mobile
to continue to benefit from non-dom status in a way that is not
appropriate for those who are firmly based in the UK.
