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Where Taxpayers and Advisers Meet

new rules iht and domicile

riccardob
Posts:105
Joined:Sun May 29, 2011 10:02 am
new rules iht and domicile

Postby riccardob » Sat Oct 24, 2015 10:23 am

hi,

i have read the brief guidance on the.gov website regarding changes to the iht regime in 2017.
the guidance states that a non domicile who has been living in the uk for 17 out of the last 20 years will be deemed uk tax domiciled. Now the guidance does not say whether there are exemptions under dual agreements with foreign countries. i am aware that under the current rules italy and the uk have a dual agreement regarding domicile status where the 17 year period is irrelevant. Does this mean that from 2017 individual arrangements with other countries are not valid anymore?

thanks

maths
Posts:8211
Joined:Wed Aug 06, 2008 3:25 pm

Re: new rules iht and domicile

Postby maths » Sun Oct 25, 2015 6:47 pm

Does this mean that from 2017 individual arrangements with other countries are not valid anymore?
No it doesn't.

The proposal post April 2017 is for deemed domicile status to apply where UK residence occurs in 15 out of 20 tax years (currently it's 17 out of 20).

Where the current deemed domicile rules are overrode in an IHT double tax agreement there is no reason to believe that this will not be the case post April 2017
subject to specific provisions to do so.


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