In view of the proposed changes to the tax legislation on residence and domicile as well as on capital gains tax which have been proposed by the current UK government, there are many resident non-domiciled individuals in the UK who are seriously considering a change of residence. Switzerland offers a number of interesting planning opportunities to those seeking to move.
Here are some of the proposed changes in the UK that are likely to have set domiciles and non-domiciles thinking: the new treatment of capital gains in trust structures of resident non-domiciled beneficiaries; reporting of such structures to HMRC; days of arrival and departure to be counted for classification of residence; capital gains tax to be charged at a flat rate of 18% without indexation or taper relief; and a charge of £30,000 a year on non-domiciles who stay beyond seven UK tax years and wish to continue to benefit from the remnants of the remittance basis.
