Navigating New Waters: Impacts of UK Government’s Non-Dom Tax Reform

Foreign Income and Gains (FIG)

• Current system: Non-domiciled individuals in the UK are currently taxed on a remittance basis, meaning you are only UK taxed on income and gains remitted to the UK.
• Proposed new system (from 6 April 2025): A shift to an internationally competitive residence-based system will be introduced meaning all worldwide income and gains will be subject to UK tax. However, a four-year relief period will be granted to new arrivals to ease the transition.

This change provides non-doms with a limited-time opportunity to remit foreign income and gains to the UK at a more favourable rate (12%), encouraging the reinvestment of global wealth into the domestic economy.

Inheritance Tax (IHT) rules based on residence

• Current system: IHT is determined by domicile status, with UK-domiciled individuals liable for IHT on worldwide assets and non-dom individuals liable for IHT on UK assets only.
• Proposed new system (from 6 April 2025): IHT liability will be based on residence rather than domicile. A new provision extends the scope of IHT to non-doms who have moved abroad, applying a 10-year window of liability. This measure ensures continued fiscal responsibility for those with substantial ties to the UK, even after they have relocated.

Trusts and Non-UK Assets

• Current system: Under current rules, UK non-doms can establish excluded property trusts to shelter non-UK situs assets from UK IHT. These trusts have provided a means of protecting assets from IHT, thus serving as an essential tool for estate planning and asset protection.
• Proposed new system: The Treasury has indicated potential grandfathering provisions for existing excluded property trusts. This potenitially means that trusts established before a specific date could retain their excluded property status, thereby exempting non-UK situs assets from IHT[2].

Settlor-Interested Trusts

• Current system: These trusts often offer tax advantages to non-domiciled individuals.
• Proposed new system: The preferential tax treatment for settlor-interested trusts will be gradually phased out, potentially leading to further tax obligations for settlors.

Strategic considerations for HNWIs and UHNWIs

With these updates, it’s crucial for non-domiciled HNWIs and UHNWIs to engage proactively with their advisors to navigate the evolving tax landscape and future proof wealth planning.

While the new government maintains continuity in many aspects of the non-dom tax regime, the introduction of specific measures marks a decisive shift towards a more inclusive and accountable tax system. Non-doms, particularly HNWIs and UHNWIs, must remain vigilant and informed to effectively manage their tax obligations and financial planning strategies.

Belasko’s proactive scenario-based analysis

At Belasko, we’re already proactively supporting our clients with scenario-based analysis to ensure they’re prepared and ready for any potential taxation impacts that will be put in place after the 30th October.

The scenario planning includes the mapping and analysis of a client’s investment universe, stress testing them against the potential changes that could be implemented by the UK government. This provides our clients with intuitive, cost-benefit analytics upon which families and their advisers can make informed decisions.

We’re experienced when it comes to optimising wealth across jurisdictions and generations and are ahead of the curve when it comes to navigating potential new tax and regulatory barriers.

Our private client directors all have 20+ years of extensive experience, leading a frontline administration and accounting service delivery team. We hold strong relationships with leading legal and tax advisors and deliver tailored solutions, while being truly dedicated to delivering client service excellence.

If you’d like to discuss how we can help you navigate new waters as a result of the new UK government, get in touch with Andy Bailey ([email protected]).

[1] https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals#:~:text=The%20government%20envisages%20that%20the,scope%20for%2010%20years%20after

[2] https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals#:~:text=The%20government%20envisages%20that%20the,scope%20for%2010%20years%20after