2017 tax changes for non-UK domiciliaries and trusts

This draft guidance is aimed at solicitors and others advising non-UK domiciled clients on the tax changes introduced by the Finance (No.2) Act 2017.

It’s been prepared by the technical committees of the:

• Society of Trust and Estate Practitioners (STEP)
• Institute of Chartered Accountants in England and Wales (ICAEW)
• Chartered Institute of Taxation (CIOT)
• Law Society (Capital Taxes sub-committee)

The questions and draft suggested answers consider areas of uncertainty in the statutory provisions for:

• Rebasing and the changes to the Capital Gains Tax foreign capital losses election – version two, 29 May 2019 (PDF 631 KB)
• Trust protections and other trust issues (PDF 207 KB)
• Inheritance tax on overseas property representing UK residential property – version three, 27 February 2020 (PDF 319 KB)
• Cleansing of mixed funds – version three (PDF 814 KB)

HM Revenue and Customs (HMRC) has not agreed any of the draft suggested answers yet, but it has commented on all of them except ‘Trust protections and other trust issues’. Apart from these comments, the draft suggested answers should not be taken as representing HMRC’s views.