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The non-doms reforms: a practitioner view

What changes have been announced?

The government has announced the abolition of the remittance basis (RB) for tax years 2025/26 onwards. Domicile as a test to determine UK tax liability will be removed and liability to UK tax going forward will depend on residence only.

Subject to making the necessary claim individuals arriving in the UK who have not been resident here for ten prior consecutive years will not pay income tax/CGT on their foreign income and gains (FIGs) for the first four continuous years of tax residence whether remitted or not. These individuals will also not pay tax on distributions from non-UK resident trusts in this period which may be extremely valuable.

After four years the above persons will pay tax on their worldwide income and gains in the same way as a UK resident would subject to any DTR in the usual way. ...

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