Guernsey Trusts for UK resident non-doms
19 March 2024
Act now to protect your clients non-UK assets from the UK inheritance tax (IHT) net.
The Spring Budget 2024 brought a shock announcement that the current remittance basis of tax for non-UK domiciliaries will come to an end on 6 April 2025.
However, IHT exemptions currently afforded to UK resident non-doms on non-UK situs assets can still be protected.
What was announced about Inheritance Tax (IHT)?
- From 6 April 2025 the government intends to move inheritance tax from a domicile-based regime to a residence-based regime. This will be subject to consultation.
- It appears, however, that there is an important window until 5 April 2025 during which a nondomiciled individual may settle non-UK assets into trust and benefit from indefinite IHT protection as under the current Protected Trusts regime. (This again is subject to consultation, but it appears the Gifts with Reservation (GWR) exemption will continue to apply to excluded property within such settlorinterest trusts. The exemptions are unlikely to apply to returning “Formerly Domiciled Residents”, as at present.)
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