The UK Bill abolishing non dom regime has passed into law with a number of small amendments to the controversial version that was first announced.
In early reaction on LinkedIn, James Quarmby, partner and head of private wealth at Stephenson Harwood said: “Yes, it’s now law, there’s no going back. The non dom regime is history, together with many of its charming eccentricities.
“The remittance basis stays alive, at least in respect of pre April 2025 foreign income and gains, but after that date, unless you are a new resident under the 4 year FIG regime, the location of your profits becomes irrelevant.
“There have been a couple of last minute amendments, but these are more about tidying up anomalies, rather than giving concessions.”
They are as follows:
• offshore trusts repatriated to the UK can now benefit from the TRF
• excluded property trusts created before 30/10/24 are now still exempt from GROB regime even if they hold non UK assets post that date
• we have a new definition of “domicile” further purposes of the limited number of capital tax treaties, which means adopting the LTR definition
