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ARTICLE · 12 NOVEMBER 2015

Deemed Domicile Post 6 April 2017

Withers LLP
Withers LLP
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Withers LLP

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The favoured tax status of foreigners planning not to stay in the UK on a long term basis (so called 'non-doms') became a hot topic in the run up to the UK General Election in May 2015, and one of George Osborne's early acts as Chancellor was to announce changes to the regime.

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The favoured tax status of foreigners planning not to stay in the UK on a long term basis (so called 'non-doms') became a hot topic in the run up to the UK General Election in May 2015, and one of George Osborne's early acts as Chancellor was to announce changes to the regime.

These do not go as far as the total abolition favoured by his opponents, but do mean that the headline tax benefits of non-dom status will only remain available to those who have been in the UK for up to 15 years – once an individual has been resident during 15 out of the last 20 tax years, he will have to pay income tax and capital gains tax on all of his worldwide income and gains in the same way as a UK domiciled taxpayer. The new 15 year 'deemed domicile' period will also apply for inheritance tax, shortening by a year the current period for which a non-dom's non UK assets are protected from tax on his death.

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