Finance Bill 2017: the non-dom reforms

Finance Bill 2017 has now been published by the Treasury, and while many of the changes expected are included in the Bill, there are some striking omissions. The proposed changes to TCGA 1992 s 87 have not been included this year. Trustees can therefore continue to ‘wash out’ gains to non-UK beneficiaries. Furthermore, the proposed new rules on intermediary payments have been deferred. The reliefs for those becoming deemed domiciled on 6 April 2017 to rebase their non-UK assets and the ability to ‘cleanse’ mixed accounts are still available. Additional legislation on loans into trusts has been included, but there is a one year grace period for individuals and trustees with existing loans into trusts to ensure they comply with the new rules.