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Collateral damage

Chris Moorcroft looks at how changes to the treatment of non-doms' inheritance tax, ownership of residential property and the remittance basis will affect prospective and current non-doms

11 November 2015

The UK tax regime for wealthy non-domiciled individuals, particularly those who are or become resident in the UK, is currently extremely uncertain. The rules are subject to frequent change, creating a problem for individuals who have based themselves in Britain, at least in part, because of its relative stability.

'Non-dom' status has become heavily politicised. In a country grappling with a vast national deficit and a public perception of increasing inequality (fueled in part by spiraling house prices) a small block of wealthy foreign individuals make an easy target both for finger pointing and revenue raising. Only the fear of a mass exodus of wealthy foreigners, taking their tax receipts and business with them, prevents the changes from being even more drastic.

With this backdrop, advising non-domiciled clients on their UK tax affairs is a tricky business, requiring co...

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