In this article for the December 2024 edition of Dutch estate planning journal Kwartaalbericht Estate Planning, Paul Hardwick, Clare Wilson and Klara Kronbergs consider the anticipated reforms to the existing “non-dom” regime, as announced at the UK Budget on 30 October 2024 and incoming from 6 April 2025, which are of the most relevance to trusts. 

The existing non-dom regime has, for many years, attracted wealthy, internationally mobile individuals to the UK by offering them beneficial tax treatment for a significant period of time. One major aspect of the regime has been that such individuals were able to set up trusts that protect non-UK assets from UK inheritance tax, income tax and capital gains tax. This generally allowed such individuals to achieve their succession objectives in a tax neutral manner.

The proposed reforms significantly alter the way in which these individuals and the trusts they have settled and will settle are taxed. This is significant as both existing structures and future planning options are affected. It is vital that UK resident non-UK domiciled individuals and structures that they have established seek advice on the effect of these rules as soon as possible.  

This article summarises:
1.  the current non-dom regime; 
2.  the new inpatriate regime; and, 
3.  how certain categories of people may be affected.

Read the full article.

The authors would also like to thank Willemijn van Duren for her contribution, noting that she is an Associate Tax Adviser in the Family Owned Business & Private Wealth practice group of Loyens & Loeff, Amsterdam.