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  • Katherine Bullock

What's on the horizon for foreign domiciles and non-residents?

This question will definitely be featuring on the top 10 that I've been asked this year. And whilst some commentators are heralding a period of stability following the extensive revision to the UK taxation of foreign domiciles and non-residents, is that right? Is that the light at the end of the tunnel or the head lights of an oncoming train?

"Will the UK feature at all on the horizon for foreign domiciles and non-residents?"

Will the UK feature at all on the horizon for foreign domiciles and non-residents? Alongside more traditional low-tax alternatives, like Switzerland, there are a wide range of jurisdictions competing to offer attractive destinations to those not domiciled there – often with far better weather – like Italy, Portugal, France and Spain. The UK in contrast is appearing less stable and, whilst the uncertainty around the tax regime is not helpful, a bigger consideration is political and economic instability.

Another equally important consideration is which country in the UK? With devolution, there is a reasonable prospect of competition within the UK itself, particularly around corporation tax rates.

The current UK landscape reflects two huge inter-connected shifts. The first covers what it means to be UK non-domiciled; the second the territorial scope of tax on UK land. As the dust starts to settle, the terrain for foreign domiciles and non-residents in the UK is very different. However, three main considerations are emerging for the well-advised. The first is to adapt and to acclimatise to this new environment. The second is to prepare for the further changes already heading our way. The third is to understand the context in which all tax planning now must operate.


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