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Deemed domicile: professional bodies revise Q&As

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CIOT, STEP, ICAEW and the Law Society have posted an updated version of their questions and answers in relation to rebasing and adjustments to the CGT foreign capital losses election, to reflect comments received from HMRC.

The professional bodies have prepared these Q&As to highlight areas of uncertainty in the deemed-domicile legislation introduced with effect from 6 April 2017. Separate drafts cover the provisions on:

  • trust protections;
  • mixed fund cleansing;
  • rebasing and adjustments to the CGT foreign capital losses election; and
  • extension of IHT to overseas property representing UK residential property interests.

HMRC does not expect to comment further on the Q&As for mixed fund cleansing and CGT rebasing, which are now expected to be the final versions.

In relation to IHT on overseas property, the professional bodies have requested further discussion on HMRC’s approach to collateral and relevant loans.

HMRC has not yet commented on the draft covering trust protections.


Issue: 1445
Categories: News