Practicalities of reintroducing withdrawn provisions raised by CIOT

The Chartered Institute of Taxation has raised concerns about the possible retrospective introduction of provisions omitted from Finance (No 2) Bill 2017.

The government stated that if re-elected it would reintroduce the dropped provisions in a new finance bill. But in a letter to the Treasury the CIOT said this could cause uncertainty for the measures that had been withdrawn but nevertheless came into force in April 2017.

The institute singled out clause 44 and Sch 15 which broaden the scope of inheritance tax to residential property in the UK and held through an overseas structure by a non-UK domiciliary.

It also cited clause 42 which extends inheritance tax to non-UK situs assets of individuals deemed to be domiciled in the UK either by virtue of their extended residence here or because the individual was born in the UK with a UK domicile of origin.

It...