28 September 2017

Changes to the taxation of non-UK trust - Round two

It has been more than two years since the government launched the most far-reaching review of the taxation of non-UK domiciliaries since 2008.

The proposals included reforms to the deemed domicile rules, changes to the inheritance tax treatment of UK residential property-holding structures, and anti-avoidance measures affecting the tax treatment of non-UK trusts.

The period since then has been marked by delays and uncertainty, including a postponement because of the snap general election. It was originally intended that all of the new rules would take effect from 6 April 2017. However, in March it was announced that they would be introduced in two stages: a first set of changes would take effect as planned on 6 April 2017, while the remaining measures would be deferred to allow more time to consider the detail.

In this briefing, we recap on the changes being introduced from April 2017, and summarise the main aspects of the further provisions that are now expected to apply from April 2018.

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