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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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Classic cars, jewellery and handbags – How high luxury is accounted for in Inheritance Tax

June 15th, 2026

Inheritance Tax (IHT) is paid on all items of your estate after you pass away if you exceed certain thresholds.

Whilst many people focus on their savings, properties and investments, the items you own, commonly referred to as personal chattels, are also included in the calculation of the estate’s value.

There has been a growing trend in recent years for people to invest in luxury goods, including cars, watches, jewellery and handbags, instead of or alongside more mainstream forms of investments, like stocks and shares.

However, many may not realise the impact that this has on their own estate, especially if the value of these assets increases significantly.

What is Inheritance Tax?

Often referred to as a “death tax” by the press, IHT is a tax on the estate, money, property and possessions of someone who has passed away.

In the UK, the standard tax-free threshold, known as the Nil-Rate Band (NRB), provides each individual with £325,000 of IHT-free assets.

On top of this, homeowners benefit from the Residence Nil-Rate Band (RNRB), which is a further £175,000 allowance if you leave your main home to a direct descendant, such as a child or grandchild.

Subject to other tax reliefs, such as Business Property Relief or Agricultural Property Relief, everything above these thresholds is taxed at a rate of 40 per cent.

A spouse can transfer any unused NRB or RNRB to the surviving spouse, which means a couple can pass on up to £1 million tax-free under the right circumstances.

As mentioned, all assets in the estate are included in your IHT calculations. This includes any classic cars, jewellery and handbags.

Unlike Capital Gains Tax, there is no general low-value exemption for personal chattels under IHT, so even modest items can form part of the estate’s overall value.

Are there ways to protect my luxury collections from Inheritance Tax?

There is a possibility that IHT could be waived on luxury collections if you are willing to part with them at least seven years before you die, thanks to the seven-year gifting rule.

This means providing clear evidence that the asset was passed on. Whilst you may be able to admire your collection from afar, you won’t be able to continue to personally possess it.

Gifted assets must be kept with the individual to whom they were gifted, as holding onto them causes them to be known as a gift with reservation of benefit and does not limit IHT exposure.

In some circumstances, you can pay a market-rate rent to use the items after making the gift, though this must be regularly reviewed to remain at market value. This approach requires careful consideration and advice.

Seeking expert support is always wise when planning your estate, regardless of how you intend to reduce IHT exposure.

Planning ahead is one of the best ways to mitigate against large IHT bills. If you have any questions about estate planning and Inheritance tax, get in touch today.

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