Non UK Domiciles - The New Tax Rules

Domicile  and Residence are separate concepts , essentially  independently determined, yet inextricably linked to form the  two sides of the coin critical in determining the current UK tax status of individuals for income tax (IT), capital gains tax (CGT), and inheritance tax (IHT). However, from 6 April 2025, ‘residence’ only will be considered for UK tax purposes.

This course focuses on the new rules and the impact on clients. Worked examples and planning points will be included as appropriate. 

A consideration of the essential impact for individuals where they have interests in non UK asset trusts will be included. This will not however include detailed guidance due to interaction with other international tax avoidance  for which bespoke specialist advice is likely to be required.

Content will include:

• The new 4 year foreign income and gains (FIG)  regime for the newly resident
• Overseas Workday Relief
• IT and CGT transitional rules for existing remittance basis users
• The impact on non UK asset trusts for IT and CGT
• The impact on Business Investment Relief
• IHT ‘long term residence’ and ‘tail’ criteria
• IHT impacts including gifting and spouse exemption
• The impact of non UK assets owned and in trust for IHT

UK residence is determined by the Statutory Residence Test rules  which are not included . This is covered in our on demand course Back to Basics International Personal Tax - Residence.