The Chartered Institute of Taxation (CIoT) said last Friday HM Revenue & Customs (HMRC)’s unpublished announcements about changes to the legislation for residence and domicile had only created confusion, as few understood which proposals were to proceed and which were to be dropped.
‘The CIoT believes the government has a golden opportunity to introduce a comprehensive, statutory residence test based on objective criteria, such as day-counting. This would afford much needed certainty in what is currently a very grey area,’ the tax institute noted in a statement.
‘Furthermore, in common with many other professional bodies and organisations, the CIoT advocates a one-year delay in implementing the proposed legislation affecting foreign domiciliaries.’
Rob Ellerby, CIoT president, said the CIoT considered the only sensible approach was to defer the implementation of the non-dom measures, in particular those relating to non-UK trusts and non-resident companies, for a year to enable ‘proper consultation’ to take place ‘with government being prepared to expose its blue-skies thinking, then its broad proposed direction of change, then the draft legislation – all in advance of the changes coming into force’.
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