The changes to the taxation of non-UK domiciled individuals introduced with effect from April 2017 caused many to rethink their connections with the UK. For those who departed, the framework of the legislation allows for the ‘re-setting’ of the domicile clock thus permitting a return to the UK with a favourable tax profile. But is this possible in reality? It is not just a matter of years of non-residence, there are the underlying principles of the common law concept of domicile to navigate. If individuals do decide to return, the temporary non-residence rules can defeat the best planning for new non-taxable sources of funding. The future of the remittance basis is also in doubt ahead of the forthcoming general election.
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The changes to the taxation of non-UK domiciled individuals introduced with effect from April 2017 caused many to rethink their connections with the UK. For those who departed, the framework of the legislation allows for the ‘re-setting’ of the domicile clock thus permitting a return to the UK with a favourable tax profile. But is this possible in reality? It is not just a matter of years of non-residence, there are the underlying principles of the common law concept of domicile to navigate. If individuals do decide to return, the temporary non-residence rules can defeat the best planning for new non-taxable sources of funding. The future of the remittance basis is also in doubt ahead of the forthcoming general election.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
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