The non-dom  regime  has always been appealing to  overseas individuals  being a generous tax break.


The March 2024 budget changed the landscape altogether for a regime that  started in 1799 when income tax  was introduced and the remittance basis was born. Gains and income for Non-UK trust will be  affected as well.


A summary of the proposed changes :

  • From  6 April 2025 an individual tax residence status will no longer  be determined by the concept of domicile. This affects those  born overseas and either already live in the UK or coming to live in the UK. For those living in the UK transitional rules will apply.


  • An individual who has  not lived in the UK for the past ten years will have a four -year tax holiday when moving  to the UK ( rather than the fifteen years at  present, using the remittance   basis). So the individual can freely bring their monies in the UK.


  • After being in the UK for four years the individual will be taxed on their world-wide income and gains.


  • For those  who are in the UK for more than  four years , the transitional rule will apply. They will be able to remit fund held overseas at a flat tax of 12% but only for the next two tax years , that is  2025-26 and 2026-27.


  • Additionally in  2025-26 any taxable  foreign income will benefit from a 50% reduction before being taxed in the UK, just for this one year.


  • On  5 April 2025 a  non-domiciled individual who have been claiming the remittance basis but  not yet  domiciled in the UK ( the  fifteen  out of the past  twenty rule applies  to be deemed domicile)  will be able to rebase their overseas assets  the value on  5 April 2019. So  the taxable gain for  post 6 April  2025  disposals will be the increase in value  from 6 April 2019 to  5 April 2025.



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