Draft Finance Bill 2017: the non-dom reforms

HMRC has now consulted on various proposals put forward by the chancellor and the result is the draft of legislation outlined below. As can be noted from previous editions of Tax Journal there have been changes along the way. HMRC has given some reliefs for those who became deemed domiciled in the UK from 6 April 2017 with some transitional reliefs the opportunity to ‘cleanse’ mixed accounts and the option for those who have paid the remittance basis charge (RBC) to rebase their non-UK assets at April 2017. There was also a major change in the way that trusts were taxed with a proposal that all distributions were taxed in the UK. This proposal was thankfully dropped in favour of protecting trusts that have not been touched after the settlor became domiciled...