HMRC publishes guidance on non-dom reforms

HMRC published guidance, on 31 January 2018, dealing with various aspects of the reforms to the taxation of non-domiciled individuals and offshore trusts contained in the Finance (No. 2) Act 2017 (FA2 2017) and the Finance Bill 2018 (non-dom reforms).

On the same day, HMRC updated its Guidance Note (RDR1): Residence, Domicile and the Remittance Basis, to reflect FA2 2017 changes to the deemed domicile rules effective from 6 April 2017.

We are reviewing the new guidance and, where it contains important clarifications to the operation of the non-dom reforms, we will incorporate these into our existing resources, which include practice notes:

We have tracked (and continue to track) the development of the non-dom reforms in Private client tax legislation tracker 2016-17: Deemed domicile and taxation of offshore trusts and Private client tax legislation tracker 2017-18: Taxation of offshore trusts: anti-avoidance.

Sources: HMRC: Residence, domicile and the remittance basis: RDR1, HMRC: Guidance: Deemed Domicile rules, HMRC: Guidance: Trust protections and Capital Gains Tax changes, HMRC: Guidance: Remittance basis changes, HMRC: Guidance: Cleansing mixed funds and HMRC: Guidance: Business Investment Relief.