The 2011 Budget has announced that non-domiciled individuals who
want to use the remittance basis of taxation will face a flat rate
charge of £50,000 when they have been UK resident for 12 or
more tax years. The £30,000 charge remains for non-doms
resident for seven or more tax years. Legislation will also be
introduced to remove the tax charge on remittances made for the
purpose of commercial investment into British business. This will
be a welcome concession. A consultation process has started on the
precise detail of the new rules, and a consultation document is
expected in June 2011.
The Chancellor George Osborne has also confirmed that a
consultation process is ongoing with a view to introducing a
long-awaited statutory residence test from April 2012. The hope is
that a statutory test will remove some of the uncertainty resulting
from interpreting Her Majesty's Revenue & Customs'
guidance on residence status. It is encouraging that the Chancellor
has announced
