Offshore trusts—capital payments to UK resident non-domiciliaries and applicable reliefs
Published by a LexisNexis Private Client expert
Practice notesOffshore trusts—capital payments to UK resident non-domiciliaries and applicable reliefs
Published by a LexisNexis Private Client expert
Practice notes
STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime
Finance ACT 2025 (FA 2025) which received Royal Assent on 20 March 2025, implements legislation to abolish the Remittance basis of taxation and replace it with a residence-based regime, commencing on 6 April 2025. FA 2025 also replaces domicile as the key factor in establishing liability to inheritance tax. Other changes include amendment of the rules determining excluded property status, the abolition of protected settlements status of offshore trusts, and changes to overseas workday relief.
For information on these changes, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26. See also: Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.
As discussed in the UK resident non-domiciliaries—tax planning Practice Note, non-domiciled individuals resident in the UK can Claim to be taxed on the remittance basis. This means that only their UK source income and gains and the foreign income and gains
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Jurisdiction(s):
United Kingdom
Related legal acts:
Key definition:
Trust definition
What does Trust mean?
An equitable obligation (ie a duty imposed by the law of equity), binding the trustee to deal with property over which he has control (the trust property), for the benefit of persons (the beneficiaries), of whom the trustee may be one, and any one of whom may enforce the obligation.
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