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PHILLIP DEARDEN reviews the ramifications of the draft legislation on residence and domicile.
KEY POINTS
- Days of arrival and departure to count.
- Capital gains of offshore companies will be attributed to UK resident but non-domiciled shareholders.
- Offshore settlements are subject to the most complex changes.
- Excess capital payments from an offshore trust will be matched by gains arising in future years.
- Importance of keeping records of trust gains.
We were alerted to impending changes to the rules governing both residence and the taxation of non-domiciled individuals in the Pre-Budget Report of 9 October 2007 (see my article Domicile and residence).
The associated press release (PBRN 18) contained little by way of detail. It was confirmed that in computing the 'day count' for the purposes of residence days of arrival and departure would be counted and there was to be a charge levied on individuals who...
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