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Important tax changes for non-doms


Significant changes affecting the UK tax status of non-domiciled individuals (non-doms) take effect on 6 April 2017 – and have far-reaching consequences for the majority of those who have previously enjoyed the tax breaks associated with non-dom status, regardless of whether they were initially born overseas or in the UK.

The remittance basis and the new 15/20-year rule

Under the new changes, non-domiciled individuals who have been a resident in the UK for 15 of the past 20 financial years will now be considered domiciled in the UK for all associated tax purposes, regardless of when they arrived.

This legislative change, known as ‘the 15/20-year rule’ effectively means that such individuals will no longer be entitled to claim the remittance basis for Income Tax or Capital Gains Tax (CGT) purposes. This means that those affected will be subject to UK tax on their worldwide income and gains.

Furthermore, for those who previously had a domicile of origin in the UK and later moved abroad, thus acquiring a domicile elsewhere, their UK domiciled status will be immediately reinstated if they return to the UK.

Non-doms’ residential property subject to UK Inheritance Tax

As of 6 April 2017, non-doms who hold UK residential property indirectly through an overseas intermediary, such as an offshore trust, will see such properties subject to UK Inheritance Tax (IHT).

Previously, residential property held in such structures would be overlooked as ‘excluded’, but under the new rules, such property – however held – will be within the scope of IHT. This means that UK IHT will be payable upon any significant IHT event, including a death, gift or ten year anniversary of a trust.

Grace period for ‘mixed funds’

Non-doms with offshore funds made up of untaxed foreign income and gains will be granted a grace period of two years from April 2017’ to rearrange these mixed funds, sell any assets and separate any funds into their constituent parts of foreign income, foreign gains and clean capital. The latter can then be remitted from their segregated clean capital account in line with previous rules.

This gives an opportunity for people to reorganise their affairs to benefit more from the remittance basis where this is still available, or where it has been used previously, as those old unremitted monies remain liable to UK tax under the remittance basis, even if they are now subject to tax on an arising basis.

Under these rules, excluded property trusts can be used as an important planning tool as they will remain an effective way of sheltering assets from UK Inheritance Tax before an individual becomes domicile.

This will also apply to those who are newly ‘deemed domiciled’ under the 15/20-year rule.

If you are concerned that these important changes to the taxation of non-doms are likely to affect you, please contact us. If you are able to get in touch sooner rather than later, our experts can determine the wider implications of these tax changes, how you will be personally affected and how we might be able to help you to mitigate any potentially heavy tax charges.

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Latest News

Sequencing short-term finance effectively is vital for avoiding the interest trap

September 2nd, 2026

For many businesses, short-term finance can provide an essential lifeline when cash flow becomes tight.

Whether a business needs support covering a gap between paying suppliers and receiving customer payments, or managing seasonal demand, the right type of finance can keep a business moving during uncertain times.

However, using short-term borrowing without a clear strategy can quickly become a slippery slope of missed payments and further injections of cash.

Choosing the right type of finance for your business

Not all types of short-term finance are designed for the same purpose, so businesses need to choose the option that best matches their needs.

An overdraft can provide a flexible cash buffer for day-to-day cash flow pressures, with interest usually charged only on the amount borrowed.

Invoice finance can help unlock cash tied up in unpaid business invoices, while a short-term loan may be more suitable for funding a specific purchase or project.

Problems can arise when businesses use one type of finance to solve an issue it was not intended to address.

A short-term cash flow gap can turn into a long-term borrowing habit, causing interest costs and fees to build up over time and reduce profitability.

How to avoid the interest trap

While short-term finance can be a valuable tool, it is important to understand the full cost of borrowing.

Some forms of finance, such as certain credit cards, bridging loans and revolving credit facilities, can have higher interest rates and shorter repayment terms.

Although these products can be useful in the right circumstances, they can place additional strain on businesses with unpredictable cash flow.

Understanding the total cost of borrowing can help avoid unnecessary expense and ensure the finance remains affordable.

Matching the right type of finance to the right business need can help businesses manage cash flow more effectively and avoid falling into an expensive cycle of debt.

How can we help?

Before you fall down the slippery slope of short-term finance, get in touch with an accountant.

We understand that short-term finance can sometimes feel like the only option.

Our team can help assess your cash flow needs, review your funding options and support you in choosing a solution that helps your business grow while keeping borrowing costs under control.

For support with short-term finance options, get in touch with our team.

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