The Abolition of The Non Dom Regime & The Changing Face of Tax Disputes

Introduction

From 6 April 2025, domicile is no longer a connecting factor for assessing chargeability to UK tax.

The non dom regime has been replaced with a residence-based test that broadly (assuming 10 prior years of non-UK residence) allows 4 years to freely enjoy in the UK Foreign Income and Gains (FIG) without suffering UK tax. Once that 4-year period is over UK resident individuals will be taxed on their worldwide income and gains.

Along with the introduction of the new 4-year FIG regime there are various transitional provisions to grapple with including the introduction of the Temporary Repatriation Facility (TRF).

UK resident individuals who have previously claimed the remittance basis and have unremitted FIG arising before 6 April 2025 can elect to designate all or part of the FIG and pay UK tax at a reduced rate of 12-15% to bring these funds to the UK.

Accountants, lawyers, and offshore trustees will need to upskill to understand the new regime.

This new virtual classroom seminar is designed to not only rehearse the new rules but to highlight significant traps/areas of uncertainty and thus areas of tax risk that are envisaged as a result of the regime change.

HMRC will no doubt pivot to capture new areas of non-compliance, so it is essential that you are alert to this if you are to be able to fend off enquires.

What You Will Learn

This live and interactive session will cover the following:

• Outline of the new FIG regime
• Ongoing importance of the remittance basis for prior years
• Outline of how TRF/rebasing will operate/the end of BIR
• Grandfathering and GROB for existing trusts and trust taxation going forward including exploring exit charges
• Exploring the motive defences
• Other issues - onward gifting, entity classification, Double Tax Treaty issues, valuation
• Increased reliance on the Statutory Residence Test
• Managing HMRC enquiries

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.