In the Summer Budget of 2015, the Government announced it would change the tax regime for individuals who have a foreign domicile (“non-doms”). The first consultation was published on 30 September 2015 which set out the detail of the proposals. A further consultation was published on 19th August 2016 and the Government published its response and draft provisions of the Finance Bill 2017 (“the Finance Bill”) on 5th December 2016.
In the 2015 Summer Budget, the Government announced further changes to the tax regime for people domiciled outside the United Kingdom (UK). The consultation paper was published on 30th September 2015 and the consultation period closed on 11th November 2015.
In 2011 the Government announced its intention to introduce a new statutory test of residence for tax purposes. The original intention was that the test would apply for the tax years 2012/13 onwards, but this was deferred to 2013/14. In December 2012 the Government published draft clauses for the new test.
UK domiciliaries are taxed on their worldwide income and gains when they are tax resident in the UK. The position for non-UK domiciliaries is different; they can choose to be taxed on the remittance basis.
It is no longer uncommon for a person’s estate to contain property and assets in several jurisdictions and, in the event of death, this can lead to complications if appropriate advice is not sought in advance.
An Employee Benefit Trust is a trust which can be established either in the UK or offshore and which is set up by a company to hold cash and other assets, for example shares, as a tax efficient way to provide benefit to employees and their families for the purpose of attracting and retaining quality staff.
An EFRBS is an unapproved pension scheme set up by an employer to provide retirement or death benefits for senior executives or employees and their families.