Last week, the UK tax authority, HM Revenue & Customs, said a further consultation focused on non-domiciled individuals will run for nine weeks, closing on 20 October 2016. The consultation document confirmed that the government plans to go ahead with previously announced reforms in the new post-referendum environment.

As expected, non-doms resident for 15 of the past 20 tax years will be treated as being deemed domiciled for all tax purposes. Among other planned changes, tax rules for offshore trusts will be amended and inheritance tax on residential property owned by non-doms through offshore structures are set be introduced from 6 April 2017.

“The government should delay the introduction until 2018 so that this final consultation can be carefully considered as it is important the rules are fixed for the long term, especially after the almost annual tinkering to the rules since the last major reforms in 2008,” said Nimesh Shah, partner at Blick Rothenberg.

“It’s disappointing that the government has not taken forward a relief or some form of relaxation when extracting properties from companies. The motive behind recent measures has been transparent ownership of residential property, and to not offer any kind of transitional rules goes against previous suggestions.”