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FORTHCOMING CHANGE relating to abolition of the non-dom regime and introduction of a residence-based regime: In the Autumn Budget 2024, the government signalled it will advance the previous administration’s proposal to scrap the remittance basis of taxation for non‑UK domiciled individuals and bring in a residence‑based regime, taking effect from 6 April 2025. For details on these changes, see Practice Note: The abolition of the remittance basis of taxation from 2025–26 and News Analyses: Autumn Budget 2024—Private Client analysis—International and Autumn Budget 2024—reforming the taxation of non-doms. This Practice Note considers how UK income tax applies to investors in open‑ended investment companies (OEICs) and authorised unit trusts (AUTs). Throughout, these investors are termed ‘individual investors’. Be aware that distinct provisions, not covered here, can apply to investors acting as financial traders. Non‑UK residents might be taxed on income and gains in their own jurisdiction of residence under local law. Tax legislation collectively labels OEICs and AUTs as authorised investment funds (AIFs)...
This Practice Note outlines key aspects of the taxation of investment income that apply specifically to discretionary trusts and interest in possession trusts. Interest Since 6 April 2016, interest is generally paid gross, without tax deducted at source. Trustees do not benefit from the savings allowance created by section 4 of the Finance Act 2016, which allows individuals to receive up to £1,000 of gross interest taxed at the nil rate. Accordingly, after the end of deduction at source, trustees may need to file a tax return to settle liabilities arising on very small amounts of interest. HMRC acknowledged the added administrative and financial burden. As a temporary measure, initially for 2016–2017 only, HMRC confirmed that trustees need not declare or pay tax on interest where savings interest is the sole income and the liability is under £100. This easement was extended to later tax years and remained in place until the 2023–24 tax year. From 2024–25, most trusts (and all death estates) with small amounts of...