The government are yet to provide the details of the tax changes for non-doms, however, it is clear that there will be non-favourable tax implications with their offshore trusts.
Provisionally, based on numerous consultations with the government, it appears that domicile will no longer be a basis for determining taxation going forward. This will effectively treat non-doms resident in the UK the same as UK doms (worldwide taxation) with their offshore trusts.
If these changes go ahead as anticipated, the income and the gains within these trusts (and often underlying offshore structures) will be subject to UK tax and the trust assets will be part of the settlor’s estate for inheritance tax purposes.
To find out how to mitigate some of these issues before the changes are enforced, please join our sister company, Charter Tax’s webinar, “Non-Doms and Offshore Trusts – Post Budget” on the 1st November.
If your offshore trusts were to fall foul of these tax changes, you may wish to consider moving them onshore to the UK. At Ludlow, as one of the largest UK trust companies, we manage thousands of high net worth clients with UK trusts. Our team comprises of experienced trust managers who have worked in the legal profession, accountants, bankers and in offshore jurisdictions, such as the Channel Islands, Singapore and Cayman Islands, who will able to assist with broad range of trusts.
Please contact us if you wish to have an initial discussion on your options and how Ludlow can assist with onshoring your trust.