FA 2012 analysis: Business investment relief for UK non-doms

FA 2008 brought in significant changes to the taxation of UK resident persons who were either non-domiciled or not ordinarily resident in the UK. Particularly it levied an annual charge of £30 000 on them for using the remittance basis of taxing their overseas income and gains if they had been UK resident during seven out of the last nine years. An unwanted consequence was that taxpayers thus affected were unwilling to bring investments from their overseas funds into UK businesses as the regulations did not differentiate between the purposes of the remittances.

In an aim to counter this disincentive the government flagged in its 2011 Budget a framework that has become the business investment relief (BIR) launched in the Budget of 21 March...