Finance Bill 2017 creates more uncertainty

It is very surprising that after months of consultations and deliberations the UK Government has announced it is dropping a number of sections to the Finance Bill that were going to be introduced from 6 April 2017.

It is expected that these clauses will be included in a further Finance Bill to be passed after the UK general election on 8 June.

The reason for the delay is to allow the provisions to be discussed with the opposition. Further the government may also have decided that some measures, such as those relating to the taxation of non-domiciled individuals, are simply too complicated to include without scrutiny or possibility of amendment.

Therefore for the time being the UK government is not introducing changes to:

• Treat non-domiciled individuals as deemed UK domiciled for all tax purposes once they have been UK resident for 15 out of the previous 20 tax years; and
• Bring all UK residential property held through offshore companies and trusts (including certain loans to fund their purchase and assets used as security for those loans) within the scope of UK inheritance tax;

However, it has not been possible to make all of these changes in time and consequently, the government has taken the view to defer publication of the provisions affected.

https://www.gov.uk/government/publications/non-domicile-taxation-technical-briefing-on-overseas-trusts/non-domicile-taxation-technical-briefing-on-overseas-trusts