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TAXguide 07/18: Deemed domicile changes – trust protections

Technical release

Published: 27 Mar 2018 Update History

Finance (No 2) Act 2017 introduced significant changes to the taxation of foreign domiciliaries. In TAXguide 07/18 ICAEW, STEP, the CIOT and the Law Society have published questions and draft suggested answers to highlight and consider areas of uncertainty in the statutory provisions for trust protections. Read a summary and download the full guide.


This guide is one of four outlining questions and draft suggested answers prepared by committee members of ICAEW, STEP CIOT and LSEW to highlight and consider areas of uncertainty in the statutory provisions introduced by Finance Act (No 2) Act 2017 with effect from 6 April 2017. They cover:

The draft suggested answers in this guide have not been agreed by or commented upon by HMRC and should not be taken as representing HMRC’s views. The Tax Faculty will update this TAXguide when HMRC’s comments have been received.

The draft suggested answers reflect the views of the committee members of the professional bodies involved in their preparation on the generic issues addressed in the questions and draft suggested answers.

The questions and draft suggested answers are intended to assist professional advisers in considering the issues, do not constitute advice and are not a substitute for professional consideration of the issues by such a professional adviser in each client’s specific context.

If you are required to advise a client outside of your experience, we recommend that you consider enlisting specialist help, for example from TAXconnect.

Full guide

The full 18-page guide contains:

   Section Questions
 A  Protected foreign source income and tainting 1-27
 B  Benefits charge ITA 2007 28-34

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TAXguide 07/18

Tax Faculty members and ICAEW members can download this guidance in full.