The Budget notes say (page 246) that:
Transfer of Assets Abroad
27. Anti-avoidance legislation designed to prevent individuals from avoiding
income tax by transferring assets abroad will be amended to ensure these
anti-avoidance provisions apply to non domiciled individuals. The
remittance basis will apply to remittance basis users.
This is a massive change. It effectively says that once a non-domiciled person is resident here they can no longer set up non-resident trusts to avoid UK tax.
Very good news!
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Don’t the rules apply already to non-domiciled people? What used to be s 739 has always successfully tracked UK source income to non-domiciled transferors, with offshore income being subject to what is effectively a remittance basis. The good news is that it is plain from the Budget Notes that offshore trusts will be alive and well for avoiding UK capital gains tax, what a climbdown that is by this left wing government.