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07 March 2024

Jeremy Hunt abolishes non-dom tax regime

Private Client partner Basil Dixon comments in Spears Magazine and The New Law Journal following Jeremy Hunt’s announcement in the Spring Budget that he will be abolishing the “non-dom tax regime”.

Both articles have been linked below with kind permission.

The scheme will be replaced by a ‘simpler, fairer, residency-based scheme’, the chancellor announced on Wednesday 6th March 2024.

In Spears Magazine, Basil comments that ‘The Chancellor has announced sweeping changes to non-dom taxation but there is no need to panic and the new regime presents attractive opportunities for the well advised client. After a week of intense speculation the Chancellor has put the final nail in the coffin of the tax regime for non-domiciled residents, which has been fading for the last 20 years. He is replacing it with a generous regime for new arrivers to the UK, available for the first 4 years of their residence, where their foreign income and gains will be completely free of UK tax. Unlike similar regimes, eg. the one in Italy, there will be no charge to access this treatment.’

In the New Law Journal, Basil continues to say that , “Resident non-doms will need to consider their arrangements carefully in light of the new rules being introduced.  Access to the remittance basis and the protected status of their trusts for income and capital gains tax will go from April 2025, but they have been given a year to get their house in order. The excluded property regime for inheritance tax may well continue, albeit in another form, though it should be possible to create excluded property trusts until April 2025. To reduce the sting of the loss of the remittance basis, our resident non-domiciled clients who hold foreign income and gains will be able to make use of a helpful Temporary Repatriation Facility, enabling them to bring their untaxed wealth into the UK at the encouraging rate of 12%, though they will need to wait for a year before this becomes available from April 2025.’

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Basil Dixon
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