ATT submission on Finance Bill legislation reforming the taxation of non-UK domiciled individuals

The Association of Taxation Technicians (ATT) has submitted comments on the Finance Bill legislation and Technical Note regarding reforms to the taxation of non-UK domiciled individuals.

Subject to Parliamentary processes, the current concept of domicile will be replaced with a residency-based tax regime from 6 April 2025. This will have implications across income tax, capital gains tax and inheritance tax. 

The ATT has highlighted a range of issues and concerns, from technical drafting points to practicalities of implementing the proposed measures, and has highlighted areas where additional guidance will be needed. Further details can be found in our full submission. 

The ATT has ongoing engagement with HMRC on these reforms. Please do contact us if you have any comments in relation to the measures.