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UK General Election 2024 – “Non Dom” and offshore trusts tax update

UK General Election 2024 – “Non Dom” and offshore trusts tax update
UK General Election 2024 – “Non Dom” and offshore trusts tax update
Wed Jun 5

Yesterday, the Prime Minister, Rishi Sunak, asked the King to dissolve Parliament for a General Election to be held on 4th July.  Parliament will close for business on 30th May until after the General Election when there will be a new Government.  What colour that Government will be, and how long it will take to form it, remembering the coalition negotiations of 2010, is clearly uncertain.

What is certain is that

  • The law remains as it was prior to the 2024 Budget
  • We have a good idea of what the Conservatives plan to do (although we have not seen any draft legislation) and
  • We have some idea of what a Labour led government might do.

We can also be fairly sure that any changes introduced by the new Government will not take effect until 6th April 2025, although that cannot be guaranteed.

What actions could you take?

If you are currently a UK resident non-UK domiciled individual or trustees of an offshore trust you should consider:

  • Settle offshore trusts, either settlor interested or not settlor interested, to pass wealth on to future generations
  • Create clean capital from trusts which have historic income and gains
  • Rebase non-UK capital assets whether held directly or in trusts, to current market value.  This could be done by a simple gift.
  • And for the longer term ensure that income of offshore trusts or their subsidiaries which has borne tax elsewhere, can be used by beneficiaries in a way such that they can obtain a credit for that tax.

Every situation is fact dependent, and there could be many other opportunities, especially if there is a living settlor who is, or is likely to become, non-UK resident.

When should you take action?

As soon as possible, but one thing remains clear, 6th April 2025 will be too late.


To discuss the opportunities available, please contact Stephen on +44 7802 878045 or email


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