23 November 2016

UK Non-Dom tax changes and offshore structures

In his annual Autumn Statement, the UK Chancellor has confirmed that planned changes to the UK deemed domicile rules and to the tax treatment of residential property held through non-UK corporations, will go ahead with effect from 6 April 2017.

These changes are broadly as originally announced in the summer of 2015, and as clarified in the UK Government's August 2016 consultation paper headed "Reforms to the taxation of non-domiciles".

As a result, we are expecting to see significant enquiries from clients restructuring their existing offshore arrangements including, in appropriate cases, so called "de-enveloping" properties by way of voluntary liquidations of holding companies incorporated offshore.

We advise on the laws of the British Virgin Islands, Cayman Islands, Guernsey and Jersey and have private wealth lawyers who can work with clients and their UK tax advisers to implement appropriate restructuring of entities established in these jurisdictions.


To find out more or to discuss your individual requirements, please contact any of us or a member of our Trusts and Private Wealth Team.