On 23 November 2016, as part of the Autumn Statement, it was confirmed that from April 2017 UK inheritance tax will be charged on UK residential property which is held indirectly by a non-domiciled individual through an offshore structure.
This will have a significant impact on offshore structures holding UK residential property. Investors should take tax advice and action, where appropriate to de-envelope, i.e. transfer property out of the offshore corporate ‘envelope’.
Also announced in the Autumn Statement was the anticipated end of the "non-dom" regime. From April 1017 UK residents who have been resident in the UK for at least 15 out of the prior 20 tax years will become deemed domiciled for all UK tax purposes. This will apply also to UK resident individuals born in the UK with a UK domicile of origin, even though they may have subsequently acquired a domicile of choice outside of the UK.