Significant changes come into effect from 6 April 2017 for the taxation of long-term UK residents who are not UK domiciled (non-doms).
From that date, non-doms who have been UK-resident for 15 out of the last 20 years will be deemed domicile for all UK taxes. The inheritance tax (IHT) legislation already treats non-doms as deemed UK domiciled once they have been resident here for 17 out of 20 years (split years count as a year). From April 2017, the deemed domicile status for IHT will trigger at the same point as income tax and capital gains tax (CGT).
These rules are harsher to those born in the UK with a UK domicile of origin who subsequently adopt a non- UK domicile of choice and then return to the UK (‘returners’). These ‘returners’ will be treated as UK domiciled when tax resident in the UK.
RMT Ref: 164/03.17.SL