Two Finance Bills were released by the government in September
only days apart: Finance (No. 2) Bill 2017, and a draft Finance
Bill 2018. The first includes all the changes to the taxation of
non-domiciliaries that were removed from the pre-election Finance
Bill 2017, and which will take effect from 6 April 2017.
Changes affecting individuals born in the UK with a UK domicile
of origin who return to the UK having acquired a domicile of choice
in another jurisdiction (formerly domiciled residents) will also
take effect from 6 April 2017, but these rules are outside the
scope of this briefing.
Finance Bill 2018 re-introduces and provides more detail on some
of the anti-avoidance provisions that were delayed due to the
complexity of the legislation involved. These measures will take
effect from 6 April 2018. There is therefore a small window of
opportunity for individuals and trustees to review structures and
implement any further tax planning before 6 April 2018.
