In the Summer Budget 2015, the Chancellor announced some major changes to the way non-UK domiciled individuals are treated.
The Government is to legislate such that, from April 2017, any person who has been resident in the UK for more than 15 of the previous 20 years will be deemed to be domiciled in the UK for tax purposes.
Additionally, from April 2017, individuals who are born in the UK, to UK domiciled parents, will no longer be able to claim non-domiciled status whilst they are resident in the UK.
It was also announced that from April 2017, UK residential property owned by non-domiciles, will be assessed for UK Inheritance Tax regardless of their residence status for tax purposes. This means that properties within trusts, corporate entities or other opaque structures will be subject to Inheritance Tax in the UK.
From April 2017, the government will also bring forward the point at which an individual who is classed as a non-domicile is deemed domiciled for Inheritance Tax purposes to 15 out of 20 years. It will also treat individuals who were born in the UK to parents who are domiciled here, as UK domiciled whilst they are in the UK.