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On 6 March 2024 the then Conservative government announced its plans to abolish the UK’s long-established ‘non-dom’ regime. Following the general election on 4 July the Labour government announced that the current tax treatment for UK resident non-domiciled individuals is to be abolished from 6 April 2025.
What is the background?
The Conservative party’s plans were to abolish the ‘non-dom’ regime and replace it with a new regime linked to the taxpayer’s residence as opposed to their domicile. The new regime broadly would provide a new beneficial tax regime to ‘temporary non-residents’ moving to the UK in which they would not pay tax on their non-UK income and gains in the first four years of UK residence (the FIG regime).
As long as the source of the income or situs of the gain is outside the UK it appears that temporary non-residents...
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