The CIOT has published detailed comments on the Finance Bill 2025 non-doms legislation covering in particular the FIG regime the temporary repatriation facility and inheritance tax. Highlights include:
proposed changes widening what constitutes a taxable remittance while the remittance basis is being abolished should be reconsidered;
a longer period where foreign income and gains are not taxed in the UK could bring economic and tax benefits rather than the proposed four-year regime for new arrivers. Overly burdensome administration around claims could also make the UK a less attractive destination compared with other jurisdictions which take a lighter-touch approach;
various detailed points are made on the temporary repatriation facility highlighting the need for greater clarity by HMRC;
further guidance on rebasing reliefs and the implications for offshore funds and trusts would be particularly helpful;
flagging up of potential issues with the IHT rules particularly concerning the use...
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The CIOT has published detailed comments on the Finance Bill 2025 non-doms legislation covering in particular the FIG regime the temporary repatriation facility and inheritance tax. Highlights include:
proposed changes widening what constitutes a taxable remittance while the remittance basis is being abolished should be reconsidered;
a longer period where foreign income and gains are not taxed in the UK could bring economic and tax benefits rather than the proposed four-year regime for new arrivers. Overly burdensome administration around claims could also make the UK a less attractive destination compared with other jurisdictions which take a lighter-touch approach;
various detailed points are made on the temporary repatriation facility highlighting the need for greater clarity by HMRC;
further guidance on rebasing reliefs and the implications for offshore funds and trusts would be particularly helpful;
flagging up of potential issues with the IHT rules particularly concerning the use...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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