The proposed changes in HM Revenue & Customs’ consultation document on the tax treatment of residence and domicile are wider reaching than the much-publicised £30,000 levy, according to PricewaterhouseCoopers (PwC).
A newly released PwC report warns the details in a HMRC consultation paper reveal the proposals significantly tighten the entire non-domicile tax regime, which is likely to affect most offshore structures and could significantly increase the amount of UK tax payable.
A higher charge than £30,000 is under consideration for those who have been UK residents for longer than 10 years, for instance. PwC suggests the alternative is to not pay the levy but instead pay UK tax on worldwide income and gains.
PwC urges non-doms to consider their options immediately and reorganise matters in what appears to be a short 'window of opportunity' between now and 5 April. Draft legislation will be published towards the end of 2007 or early 2008 - and it is only then the full impact of the changes will be known.
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