The CIOT would like to see commencement of the government’s non-domicile reforms deferred until 6 April 2018, but with the ability to elect into deemed domicile from 6 April 2017.
The CIOT would like to see commencement of the government’s non-domicile reforms deferred until 6 April 2018, but with the ability to elect into deemed domicile from 6 April 2017.
The comments are made in a letter to the Treasury concerning the possible re-introduction in the Summer Finance Bill of the provisions on deemed domicile and transfer of assets abroad (clauses 41 to 43 and schedules 13 and 14) omitted from Finance (No 2) Bill 2017.
The CIOT suggests that taxpayers who would have become deemed domiciled from 6 April 2017, had the proposals had been enacted, should be allowed to elect into deemed domicile status from that date. This would, the CIOT argues, provide an ‘equitable solution’ for those who have already acted on the assumption that the reforms would have effect from 6 April 2017, ‘particularly in respect of the measures such as rebasing of foreign assets that have the policy intent of assisting affected taxpayers to adjust to the new regime’.
In May, the CIOT wrote to the Treasury for clarification in relation to specific tax charges which could arise in the interim period between 6 April 2017 and the introduction of a post-election Finance Bill.
The CIOT would like to see commencement of the government’s non-domicile reforms deferred until 6 April 2018, but with the ability to elect into deemed domicile from 6 April 2017.
The CIOT would like to see commencement of the government’s non-domicile reforms deferred until 6 April 2018, but with the ability to elect into deemed domicile from 6 April 2017.
The comments are made in a letter to the Treasury concerning the possible re-introduction in the Summer Finance Bill of the provisions on deemed domicile and transfer of assets abroad (clauses 41 to 43 and schedules 13 and 14) omitted from Finance (No 2) Bill 2017.
The CIOT suggests that taxpayers who would have become deemed domiciled from 6 April 2017, had the proposals had been enacted, should be allowed to elect into deemed domicile status from that date. This would, the CIOT argues, provide an ‘equitable solution’ for those who have already acted on the assumption that the reforms would have effect from 6 April 2017, ‘particularly in respect of the measures such as rebasing of foreign assets that have the policy intent of assisting affected taxpayers to adjust to the new regime’.
In May, the CIOT wrote to the Treasury for clarification in relation to specific tax charges which could arise in the interim period between 6 April 2017 and the introduction of a post-election Finance Bill.
