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Finance Bill tax clauses return from temporary limbo


The second finance bill of the year will be published today (Friday 8 September), resurrecting most of the tax clauses that were announced in the budget in March but dropped in the parliamentary wash-up just before the June general election.
The Westminster parliament's website refers to it as Finance Bill 2017-2019, as it was announced in the Queen's speech that the current parliamentary session will last two years. However, it is expected to be enacted as Finance (No.2) Act 2017.

What will change

A summary of the 48 clauses to be included has already been made available. Although the bill is unlikely to be enacted for several weeks yet, at least 34 of the provisions will take effect retrospectively starting on 1 April or 6 April 2017, or in some cases even earlier. They include the deemed-domicile reforms for non-doms; the property and trading incomes allowance of GBP1,000 each; restricted carry-forward of corporate losses; the cash basis accounting concession for landlords; the GBP4,000 restriction on the money purchase annual allowance (MPAA) for pension contributions; and restrictions on the enterprise investment scheme.
The bill also makes retrospective provision for overseas property with value attributable to UK residential property to be chargeable to UK inheritance tax.

Changes to non-dom regime

There is now no doubt that the non-dom tax regime will be amended as promised, with effect from April 2017. The changes, concerning inheritance tax for deemed domiciles and overseas property held in offshore structures, are generally unwelcome for non-dom taxpayers but at least the uncertainty is now almost over. Some additional changes were originally mooted by the Treasury but were not included in last April's finance bill; they will make their first appearance in the text of the bill to be published today.
This article will be updated.
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