Expats ‘hardest hit’
Jackie Hall, tax partner at consultancy firm RSM, said: “The hardest hit group of individuals are returning expats who will now be deemed domiciled for all tax purposes while they are resident in the UK.
“What this means is that someone who was born in the UK but has lived all their life overseas with no intention of returning to the UK to live can be deemed domiciled simply because they are seconded to the UK by their employer for say six months, or have to return temporarily to look after a sick relative. The fact that these individuals may retain a foreign domicile under general law is irrelevant,” she said.
Two-year window
Hall added that despite there being two-year window to tidy up overseas accounts containing mixed funds of capital, gains or income so that tax efficient remittance can be made in the future, any such structure will need to be in place before 6 April 2017 to be fully effective.
“The Finance Bill is not yet legislation. Indeed it is barely at the start of its legislative process and taxpayers are having to plan around the uncertainty of what happens if the bill is not approved in its draft form.
“While it is unlikely that any substantial changes will be made, given the lengthy period of time and debate it has taken to get the new rules this far, this ongoing uncertainty is far from satisfactory,” she said.
