Press release

Government consults on reforms to the taxation of non-domiciled individuals and a statutory definition of tax residence

皇冠体育app Government is today publishing a consultation on its plans to reform the taxation of non-domiciled individuals (鈥渘on-domiciles").

This was published under the 2010 to 2015 Conservative and Liberal Democrat coalition government

皇冠体育app Government is today publishing a consultation on its plans to reform the taxation of non-domiciled individuals (鈥渘on-domiciles鈥�). It wants to ensure that non-domiciles make a fair tax contribution, as well as encourage them to invest in the UK and simplify the current tax rules for them.听

皇冠体育app consultation provides details on the package of reforms that were announced at Budget 2011 and will increase the tax charge for certain long-term resident non-domiciles to 拢50,000, provide a significant new incentive for non-domiciles to invest in the UK and simplify the rules to reduce administrative burdens.听 皇冠体育app Government does not intend to change the broad principles behind the existing tax system for non-domiciles.

皇冠体育app current rules discourage non-domiciles from bringing their income or capital gains to the UK, creating barriers to potential investment in the UK economy.听 皇冠体育app Government鈥檚 aim is to remove these barriers so that non-domiciles are encouraged to invest in UK business, contributing to its priority of generating growth and rebuilding the economy.听 However, a balance must be struck to ensure that they make a fair contribution.

David Gauke, Exchequer Secretary to the Treasury, said:

皇冠体育app Government wants to ensure that the rules of our tax system are fair.听 That is why we are increasing the tax charge for those non-domiciles who have been resident in the UK for long periods of time.听 At the same time, it is important that skilled individuals and investors are encouraged to come to the UK from abroad and we recognise the fact that non-domiciles can make a valuable contribution to the UK economy.听 That is why we want to make it easier for them to invest in UK business.

皇冠体育app Government is also today publishing a consultation on its plans for a statutory residence test (SRT).听 皇冠体育appre is currently no full legal definition of tax residence, meaning that the rules are unclear, complicated and seen as subjective.听 This creates uncertainty for individuals about their residence status and is a deterrent to businesses and individuals considering investing in the UK.听 Today鈥檚 consultation proposes a framework for the SRT and seeks views on its design and implementation, in order to address these issues.

Both consultations published today close on 9 September 2011.听 A summary of responses to both will be published in the autumn.听 Draft legislation will be published for comment later in 2011 with a view to including final legislation in Finance Bill 2012.

Notes for Editors

  1. 皇冠体育app consultation document on the reform of the taxation of non-domiciled individuals can be found in our consultation area:

  2. 皇冠体育app tax systems of all countries need to distinguish between permanent residents and those from abroad who have less connection with the jurisdiction. 皇冠体育app UK does this using the well-established concept of domicile and recognises the limited nature of non-domiciles鈥� links to the UK by having a dedicated set of tax rules for them. Under these rules, individuals who are resident but not domiciled in the UK are:

    • liable to UK tax on all their income and capital gains which arise in the UK
    • but only liable to UK tax on non-UK (鈥渙verseas鈥�) income and capital gains if they are remitted to the UK
  3. 皇冠体育app Government鈥檚 package of reforms, announced at Budget 2011, includes the following measures:

    • increasing the existing 拢30,000 annual charge to 拢50,000 for non-domiciles who claim the remittance basis in a tax year and who have been UK resident in 12 or more of the 14 years prior to the year of claim
    • allowing non-domiciles to bring overseas income and capital gains to the UK tax-free for the purpose of commercial investment in UK businesses
    • simplifying the way in which some aspects of the current rules work
  4. To provide stability and certainty for non-domiciles, there will be no further substantive changes to their taxation for the remainder of this Parliament.

  5. 皇冠体育app consultation document on a statutory definition of tax residence can be found in our consultation area: 听

  6. By introducing an SRT, the Government aims to make the rules simpler and clearer but the tax residence status of the vast majority of people will be unaffected.

Non-media enquiries should be addressed to the Treasury Correspondence and Enquiry Unit on 020 7270 4558 or by e-mail to [email protected]

Media enquiries should be addressed to the Treasury Press Office on 020 7270 5238.

Updates to this page

Published 17 June 2011