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CIOT submission on non-domicile taxation

The CIOT has sent a submission to HMRC on non-domicile taxation reforms which may require legislative change and clarification. The submission sets out several technical and legislative issues following the enactment of the Finance Act 2025 changes.

The submission details several areas of concern for UK tax practitioners. It highlights that, following enactment of the FA 2025 changes, significant omissions and uncertainties remain in the new non-domicile regime. The CIOT considers that technical issues, such as consequential claims for relief on foreign income and gains and matching rules for chargeable gains in relation to both income tax and capital gains tax, require further legislative clarification or amendment to ensure simplicity, certainty, and consistency.

In addition, the submission discusses complexities arising from the new provisions affecting trusts, remittance rules, and the Temporary Repatriation Facility (TRF). It suggests that issues, including the treatment of overseas capital, dates of conversion of foreign income, and the potential for double taxation or multiple tax charges, be reviewed. The CIOT also raises points on