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Future of the non-dom: let's discuss


We would be delighted if you would join us for an open discussion, on a Chatham House basis, over breakfast to discuss the outlook for the non-dom regime.

In light of the Labour party's pledge to abolish non-dom tax status if they are elected we have been reflecting on the consequences of recent changes to the regime (both direct and indirect) and the impact they have had on the non-dom community and those looking at alternative residences. Over the past 15 to 20 years, indeed, the time it might take someone to become deemed domiciled, there have been wholesale changes to the approach the Government has taken to people arriving in the UK.  We have been asking ourselves what the future has in store for overseas investors and people looking to change residence using our experience and knowledge of how the introduction of the remittance regime in 2008 impacted non-doms living in the UK, as well as fallout of the 2017 changes to the deemed domicile rules, the closure of the investor visa and the introduction of ATED.   

Over 75,000 people claimed the remittance basis in the year to 6 April 2020. London prime property made up the greatest proportion of ATED receipts (85%) in 2020/21. According to research published by CAGE Warwick and LSE International Inequalities Institute, more than one in 10 adults living in Kensington and the Cities of London and Westminster is a non-dom and more than one in five top-earning bankers is a non-dom. With this data in mind, any radical changes, like the abolition of the regime proposed by Labour, are likely to impact current investment and immigration patterns.  

We will discuss how past changes, such as those in 2008 and 2017, affected the behaviour of RNDs and what the future holds for this demographic given the potential for regime change.

Please join Charlie Sosna, Partner and Head of Private Tax and Wealth Planning, Steven Bostock, Partner and Head of Immigration and James Liffen, Partner in Residential Property for a roundtable discussion to be chaired by Carol Katz, Partner in Private Tax and Wealth Planning.

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