Draft Finance Bill 2017: the non-dom reforms

Many of the draft Finance Bill 2017 changes are as expected – although not entirely so for the new ‘protected settlements’ regime. Unfortunately though what the draft Finance Bill doesn’t do is to go very far in making the business investment relief rules more favourable. There is some relaxation of the extraction of value rule; an ability to now buy shares rather than just subscribe for them; and the two year set up rule has been extended to five years. Otherwise we will have to wait for further consultation for some more meaningful changes. It is also fairly clear that some of the draft Finance Bill 2017 legislation will require some further work to obtain the necessary clarity before it hits the statute books. For sure though non-doms who will become deemed domiciled on 6 April 2017 will need to now hurry up and make sure...