Non-doms and nil rate bands: Six ‘Emergency Budget’ predictions
By International Adviser, 19 Jun 15
Chris Groves and Sophie Dworetzsky from international law firm Withers outline six of their expectations for July’s Budget.
Osborne has been robust in his defence of the remittance basis regime, claiming in the General Election campaign that abolishing ‘non-dom status altogether would cost our country hundreds of millions of pounds in lost tax revenues and lost investment’.
However, leaving the regime in its current form does not seem to be in the Conservatives’ plans either; the remittance basis charge which was increased to a maximum of £90,000 in the April Budget looks likely to increase further.
The proposal to allow non-doms to elect for the remittance basis only on a triannual basis also looks likely to proceed. So will there though be a more far reaching reform of the non-domicile regime?
How might the domicile be changed?
Perhaps the first point to make is that it seems unlikely that the concept of domicile, which has implications far wider than simply an individual’s tax profile, will itself be amended.
Instead, it is likely that only the basis for qualification for the remittance basis would be changed. Politically the greatest pressure for reform seems to fall on three categories of non-dom:
- The inherited non-doms – there are an increasingly large category of ‘2nd generation’ non-doms being born and brought up in the UK, but who retain a domicile outside the UK
- The long-term resident non-doms – perhaps more colloquially described as ‘the ones who are never going to leave are they…’
- Returning non-doms – UK doms who have left the UK and acquired a domicile elsewhere only to return to the UK as non-doms
Tags: Non Doms | UK Adviser | Withers
