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Reform of Taxation of Non-UK Domiciled Individuals

Last month’s UK general election result did nothing to clarify the uncertainty regarding the proposed tax reforms for non-UK domiciled individuals.

NonUk Dom IndThe draft legislation, for these reforms, was omitted from Finance Bill 2017, so that the critical revenue-raising measures could pass in time for the general election. The feeling in the tax community was that these reforms would be quickly reintroduced, in a second budget, following a decisive Conservative election win.

The UK electorate had other ideas, and with Philip Hammond now ruling out a Budget before the scheduled one in November, it seems unlikely that these reforms will be reintroduced for the 2017/18 UK tax year.

A delay to the introduction of these measures could, in fact, prove useful, as it would give HMRC time to publish much needed practical guidance on key aspects such a foreign asset rebasing and mixed fund cleansing. However, some taxpayers have been left in limbo as they acted in the expectation of these reforms being applicable for 6 April 2017. This uncertainty has left them in a position of having to delay acting on planning opportunities, and in some cases, facing an unexpected UK tax bill.

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