Proposed changes, likely outcomes and opportunities
Lisa Cornwell, Tax Partner, International Wealth and Family Offices, PwC Switzerland, Zurich
The UK “Res Non-Dom” regime was the original regime designed to attract foreign investors to the country that has been copied in multiple countries and has successfully attracted many wealthy individuals to live in the UK over the decades.
However, in the Spring Budget in March 2024, the death knell was struck for this basis of taxation. Against a turbulent backdrop, what are the key issues that international families, businesses and family offices should be considering?
We will review the proposed changes and the likely outcomes and planning opportunities arising for clients to consider.
Overview of the current state of play
- Outlining the political landscape
- Backdrop to the changes
The proposed new rules
- The four year rule
- Encouraging UK remittances
The inheritance tax question
- 10 year “top and tail”
- The End of Domicile?
The impact on existing international structures
- What trustees should be thinking about now?
- How are family offices impacted?
- Any quick fixes?
- The alternatives?
Likely outcomes going forward
- Increased focus on residence position
- The UK as a short-term home
- Capital gains v income
- The business environment
- Inward investment into the UK
- Interaction with other tax regimes (double tax relief)
Should I stay or should I go?
- Helping clients decide on their next step
- Which options are popular?
- Stepping through considerations
SPEAKERS
Lisa Cornwell
Tax Partner, International Wealth and Family Offices
PwC Switzerland, Zurich
The Changing UK Landscape and its impact on international families
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