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Carrot and stick

02 August 2011 / Emma Chamberlain
Issue: 4315 / Categories: Comment & Analysis , Residence & domicile

Reviewing the latest consultation paper on domicile reform

KEY POINTS

  • Remittance basis charge to be increased for some non-doms.
  • Rules for remittance basis to be improved.
  • New relief for sales of art and chattels.
  • Qualifying for business investment relief.
  • Interaction of mixed funds with the new relief.

In June 2011 HMRC and HM Treasury published a consultation paper called The Reform of the Taxation of Non-Domiciled Individuals. The consultation period closes on 9 September 2011 and the aim is to introduce changes with effect from 6 April 2012.

The paper is a mixture of carrot and stick. As announced in the Budget 2011 the government aims to strike a balance between increasing the tax contribution made by non-domiciliaries and encouraging them to invest in the UK. There are four main proposals:

  • an...

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