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How to handle the cleansing and mixed funds rules

The cleansing and mixed fund rules present a unique opportunity for non-UK domiciliaries to access clean capital for UK expenditure. Emma Heelis-Adams (Burges Salmon) explains.
 

Since April 2017 the remittance basis of taxation has not been available to non-UK domiciliaries (non-doms) who have been resident in the UK for at least 15 out of the previous 20 tax years. This change means that many long-term UK residents who were previously taxed on the remittance basis are now subject to tax on their worldwide income and gains.

A quid pro quo for the removal of access to the remittance basis of taxation was the opportunity for non-doms to ‘cleanse’ offshore mixed funds. This opportunity is only available until 5 April 2019 and due to the complexity involved in many cleansing exercises non-doms must act now otherwise they risk not having sufficient time to complete the process.

If untaxed...

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