1 General news
1.1 Government nearly consults on tax reform of
non-domiciliaries
The Government released and then promptly withdrew the promised
consultation on the taxation of non-domiciliaries (non-doms). Two
key proposals are that (i) non-doms who have been resident in the
UK for 15 out of 20 years will be deemed UK domiciled for tax
purposes and (ii) individuals born in the UK with a UK domicile of
origin will regain that domicile status if they return to the UK.
Changes around offshore trusts are also mentioned, but will take
place at a slower rate.
Note: These comments have been prepared on the
basis of the version of the proposed consultation placed
in the public domain online and almost immediately withdrawn,
although we understand that there are unlikely to be any
substantial changes to the final version.
However, the following notes must be treated with due
caution. We nevertheless anticipate that many
taxpayers will be interested in the draft
