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Deemed domicile for income tax, IHT and CGT: revised draft legislation

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HMRC has published a revised version of the draft Finance Bill legislation introducing deemed UK domicile rules for income tax, CGT and IHT purposes from April 2017.

HMRC has published a revised version of the draft Finance Bill legislation introducing deemed UK domicile rules for income tax, CGT and IHT purposes from April 2017. The revised draft amends the schedule to contain an exception for protected foreign-source income of overseas trusts and additional conditions for transfers from mixed funds. Comments on the revised draft are invited by 23 February 2017.

Draft Finance Bill legislation introducing deemed-domicile provisions for income tax, CGT and IHT was published on 5 December (clauses 40, 41 and Sch 12).

The revised draft schedule now contains new paras 20 to 39, containing further amendments to ITTOIA 2005 and ITA 2007 providing an exception for protected foreign-source income of overseas trusts.

New paras 44(4) and (5) have been added to provide further conditions for transfers from overseas mixed funds.

Issue: 1340
Categories: News
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