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ARTICLE · 24 OCTOBER 2007

Pre-Budget Report - Changes Affecting Non-UK Domiciliaries

Smith & Williamson
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For many years changes to the basis of taxation for non-UK domiciled individuals have been anticipated, but successive governments have found the issue too difficult to tackle. This is no longer the case.

United KingdomTax

For many years changes to the basis of taxation for non-UK domiciled individuals have been anticipated, but successive governments have found the issue too difficult to tackle. This is no longer the case.

In the Pre-Budget Report (PBR) of 9 October, the Chancellor of the Exchequer, Alistair Darling announced sweeping changes to the way non-UK domiciled individuals resident in the UK will be taxed. While the proposals were short on detail, it is clear there are a number of areas where clients will have to give serious thought as to how best to organise their affairs going forward.

Who Is Affected?

Some of the new rules apply to all non-UK domiciled individuals while others apply specifically to non-UK domiciled individuals who have been resident in the UK for tax purposes for seven years or more. Currently it is unclear if this means seven consecutive fiscal years or any seven years over a longer period. Care will have to be taken in determining years of residence, as in reality if

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