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Spring awakening: Private client changes in the Budget

David Kilshaw and Sophia Watsham review the Spring Budget and the changes introduced by the latest Finance Bill from the private client perspective

19 April 2016

The Finance (No. 2) Bill 2016 (which for ease is here referred to as the Finance Bill) was published on 24 March 2016. It may have contained over 570 pages, but it did not give private client practitioners what they most wanted: fuller detail on the changes relating to non-domiciled residents (non-doms), which are scheduled to be enacted from 6 April 2017. The Finance Bill was silent on this key area; HMRC in fact announced that all non-dom legislation will be enacted in the 2017 Finance Act.

Despite the Bill's silence on the topic, there was one important piece of news in the non-dom arena on Budget day. It was announced that there would be a rebasing of assets for capital gains tax (CGT) purposes for non-doms becoming deemed domiciled on 6 April 2017.

This is a positive development, but problems and questions remain as to its scope. Will it apply to assets held in trusts or only those hel...

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