From 6 April 2017, a non-domiciled individual who has been UK tax resident in at least 15 of the previous
20 UK tax years will be treated as domiciled in the UK for all UK tax purposes, and will no longer be able to
make a claim to be taxed on the remittance basis.
To compensate, two valuable transitional reliefs have been introduced:
i. All non-UK domiciled UK resident individuals (except returning non-doms) have a one–off
opportunity to re-organise offshore mixed funds into their constituent parts. Allowing them to
identify “clean capital” which can be remitted to the UK tax free;
ii. Individuals becoming deemed domiciled on 6 April 2017 under the 15 out of 20 year rule will be
able to benefit from rebasing of their foreign situated capital assets to their market value on 5 April
2017, for CGT purposes.
These mixed fund cleansing and rebasing opportunities are invaluable to long term residents of the UK
All non-domiciled individuals, whether they have been claiming the remittance basis or not, should review
their affairs before the new rules come into force.
Please contact our non-dom experts Julian Brooks and Jamie Favell to discuss how we can assist you.
