Since the original announcement made by the HMRC UK, on changes to the UK tax laws in 2015, a number of consultations, delays and further announcements were made throughout 2016 leading to indicate that the implementation of the changes will happen on 6 April 2017.

This caused a rush of planning for possible re-structuring by many consultants in 2016. Subsequent political factors further delayed the implementations and an announcement was made in September 2017 that the changes will take effect retrospective from 6 April 2017.

Whilst a number of factors are still being clarified, the takeaway points from the talk by Mr. Nick Jacob - Partner, Private Client, Fosters were:

  • Non domicile residence will be considered as Deemed domiciled from the 15th year of residence in the UK, thus be liable to world-wide tax basis
  • To review possibilities of creating new trusts or adding assets into existing trusts before being deemed as domicile, so that UK Inheritance Tax (IHT) matters can be addressed
  • NOT to add in any further assets into the trust after being deemed domiciled
  • To keep good records of all acquisition costs and values and to make election in year of disposal
  • Trust is still a good planning tool
  • To be careful of tainting the trust e.g. loans must be with commercial interest rate
  • There are new rules on valuation of benefits
  • For UK residential property owned under a company or partnership no longer protected from UK IHT
  • Anti-avoidance provision will catch any arrangements to avoid IHT

43 attended the talk, most were from the banking and trust industry.

Click HERE to view event photos.

Contributed by: 

Ms Linda Wong

Managing Director, Kensington Trust Singapore Limited



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