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A new tax landscape for non UK domiciled individuals

Posted on 8 November 2024

Our Private Wealth and Tax team hosted a digital session on Thursday 7 November where we clarified some of the complexity surrounding the new rules and gave you some points to consider and guidance on possible actions to take. Please see the recording of the session above.  

Here is a summary of the key takeaways:  

  • The 4-year FIG regime replaces the non-dom regime from 6 April 2025 - there is no fee to access the FIG regime 
  • During the 4-year period in which the FIG regime applies foreign income and gains (FIG) are not taxable in the UK 
  • After 10 consecutive tax years of UK residence a person will be subject to inheritance tax (IHT) 
  • The IHT tail will be for a minimum of 3 years and a maximum of 10 
  • The importance of the statutory residence test – and record keeping – increases from 6 April 2025 
  • Non-UK trustees with UK resident settlors have a lot to think about and not much time before 6 April 2025 – settlements need to be reviewed, discussions need to be had with settlors and beneficiaries and advice sought as soon as possible 

You can find more of our insights on our UK Government reform hub and our non-dom hub

 

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