Foreign Domiciled People
As previously announced, there are significant reforms of the tax treatment of foreign domiciled people from April 2017. Those who have been resident in the UK for 15 of the previous 20 years will lose their foreign domiciled status and will be taxed in the same way as UK domiciled individuals. People born in the UK with a UK domicile, who have acquired a foreign domicile of choice, will be treated as UK domiciled again if they subsequently become UK resident.
In addition, UK residential property held by a foreign domiciled individual through offshore structures becomes chargeable to Inheritance Tax. However, a foreign domiciled person who sets up a foreign resident trust before becoming deemed UK domiciled can use that structure to shelter gains and income from UK tax.