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Non-domicile taxation and overseas trusts

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Draft legislation published in December and January aimed to ensure that income and gains arising in overseas trusts created by non-domiciled individuals before they become deemed domiciled under the 15/20 test would not be taxed if they are retained in the trust or its underlying entities. HMRC has published a note advising that it has not been able to incorporate all of the changes arising from issues raised during the consultation in time for inclusion in the current Finance Bill. The note sets out the provisions that have been published in the Finance Bill 2017 and those that will be included in a future Finance Bill. It also contains a summary of changes made since the January draft.