Draft Finance Bill 2016 Clause 67 Civil penalties for enablers of offshore tax evasion - CIOT comments
It also proposes a new rule to provide that an individual born in the UK with a UK domicile of origin who has acquired a domicile of choice elsewhere will be treated as domiciled for IHT purposes if at any time they are resident in the UK and have been resident in the UK in at least one out of the two previous tax years. The draft clause does not take account of responses made to the September 2015 Consultation and so we await publication of the revised version. Meanwhile we repeated the comments we made last year, and highlighted the need for clarity in the commencement provisions.
The full CIOT response can be found here.