For trustees and settlors, the upcoming changes to the UK tax regime pose significant challenges, particularly for those managing settlor-interested trusts. The impending reforms, combined with an intensified focus from HMRC on tax investigations, create a complex environment where strategic planning is more critical than ever.
For those who may be affected, the recent changes to the UK tax regime for resident non-domiciled individuals (RNDs) are significant. The announcements in the March Spring Budget and the new Labour Government’s proposals have created a pressing need for immediate and strategic planning.
The Labour Party’s proposal to modify non-dom status, including a potential four-year grace period for new non-doms and a projected decrease in revenue generation, has introduced more questions than answers.
The publication of Spotlight 63 in October [Property business arrangements involving hybrid partnerships (Spotlight 63) – GOV.UK (www.gov.uk)](https://www.gov.uk/guidance/property-business-arrangements-involving-hybrid-partnerships-spotlight-63) and the issue of “nudge letters” this month by HMRC to users of a “hybrid scheme” designed to benefit from lower corporation tax rates and unrestricted interest relief for landlords, looks to be the start of an awakening by HMRC to the abuses of incorporation relief in the property sector.
Non-domiciled tax status, a political hot potato if ever there was one, has been around in one form or another since 1799. Since then, the regime has undergone a plethora of changes...
HMRC won in the recent First Tier Tribunal in the case of Ian Strachan, TC8858. This is a case where the taxpayer argued that he had acquired a domicile of choice in Massachusetts.
