Finance (No 2) Act 2017 introduced very significant changes to the taxation of non-UK domiciliaries.
These questions and draft suggested answers have been prepared by committee members of the CIOT, STEP, ICAEW, and the Law Society to highlight and consider areas of uncertainty in the statutory provisions for trust protections, mixed fund cleansing and rebasing as introduced by Finance (No) Act 2017 with effect from 6 April 2017. The questions and the draft suggested answers have been sent to HMRC for comment.
The draft suggested answers have not been agreed by or commented upon by HMRC at this stage and should not be taken as representing HMRC’s views. We will update the documents when HMRC’s comments are received.
The draft suggested answers reflect the views of the committee members of the professional bodies involved in their preparation on the generic issues addressed in the questions and draft suggested answers. The questions and draft suggested answers are intended to assist professional advisers in considering the issues, do not constitute advice and are not a substitute for professional consideration of the issues by such a professional adviser in each client’s specific context.
- Q&As Trust protections
- Q&As Mixed fund cleansing
- Q&As Rebasing and the adjustments to the CGT foreign capital losses election
These documents are also published as TAXguides by the ICAEW Tax Faculty.