Member

Finally, the Government have proposed 11 technical amendments to the new residence-based system for inheritance tax. These changes ensure that the new rules work as intended by addressing a mismatch between the new long-term UK residence test and the old inheritance tax rules for deemed domicile when it comes to operating within several of the UK’s double taxation agreements. The Government have also tabled several amendments to provide clarity on the treatment of existing excluded property trusts, while also relaxing the test for whether the inheritance tax carve-out applies. As a result, the property will only need to be offshore immediately before the transfer or the settlor’s death, rather than being kept offshore until that time. That easement will enable trusts to invest in the UK in the interim, thereby helping to grow the economy.