In the current economic climate the tax advantages associated 
with non-domicile status are a hot topic.
Recent developments including the UK/Swiss deal (which potentially affects UK-resident non-domiciled offshore account holders) emphasise this.
For taxpayers who claim non-domicile status it is key to their compliance and financial planning that such a position is agreed by HMRC.
Clarity around non-domicile status is particularly important for High Net Worth Individuals (HNWIs) or ‘affluent’ taxpayers as the financial consequences of a dispute may be severe. HMRC encourages pre-filing agreement with large corporates and HNWIs in other technical areas but seem averse to doing the same where non-domicile claims are concerned.
HMRC recently consulted on potential changes to the non-domicile rules. These included proposals to facilitate investments...
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