If you are about to become deemed UK domiciled under the new rules, applicable from 6 April 2017, consider carrying out some pre-year end tax planning.
From 6 April 2017, the new deemed domicile rules apply.
Individuals who are currently non-domiciled, but who will become deemed domiciled under the new rules on 6 April 2017 (or later), should consider the following planning actions:
- transfer any non-UK assets to an offshore trust: offshore trusts that are settled before the individual is deemed domiciled, will still be capable of being ‘excluded property trusts’ and outside the UK IHT net.
- for those that are currently non-domiciled and claiming the remittance basis, but who will become deemed domiciled under the new rules, you should open a new account which can receive your non-UK income and gains from the date you become deemed domiciled. This account can be based in the UK or abroad. The funds in this account can be remitted to the UK as it will be taxed on the arising basis. You can leave the income and gains in from before you were deemed domicile offshore and outside the UK tax net.