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Update: Non-UK domiciles and IHT changes

Further to our email announcement on 26 April 2017 (please click here) the Government has announced that it will go ahead with the changes to the taxation of non-domiciles and the Inheritance Tax charges on UK residential property owned in trusts and companies. This includes the mixed foreign account cleansing and rebasing provisions.


As originally proposed, the changes will take effect from 6 April 2017. However, the legislation is still in draft and we cannot be absolutely sure that the changes will be implemented in accordance with draft legislation until the Finance Act becomes law. This will not be until late October or November at the earliest.

In view of all of the uncertainty to date, we recommend a cautious approach is adopted and, where possible, no action is taken which could give rise to a tax liability (such as remittances to the UK following the cleansing of mixed funds or rebasing) until the Finance Bill becomes law. If it is not possible to postpone a transaction, please speak to us first before any arrangements are made.


If you would like to discuss this further please contact a member from our Private Client team or your usual Mercer & Hole contact.

 

 

Date: 26th July, 2017
Author: Alice Pearson

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