Non - Domicile pre 2008
We have been a approached by a prospect to sort his outstanding tax situation under Liectenstein Disclosure Facility. He has undisclosed foreign source income from self employment foreign contracts for periods from 2001 to 2010. This income was paid into and held in an offshore account.
It is much likely that he will be treated as non-domicile based on 'domicile of origin' under the pre-2008 rules. He could have therefore possibly availed the remittance basis for the periods to 2008. He has also been filing tax returns through his current accountants all these years. However they never disclosed this income nor ticked non-domicile status in the tax returns (no Dom1 forms filed either) , though they advised him to keep the income outside to avoid UK tax charge.
Is it now possible to go back and claim non-domicile for periods from 2001-2008 and pay tax only on the amounts remitted to UK during the period?
From the initial conversations he indicated remittance during this period was only around 25% of the income earned/ held offshore.
I am conscious of the changes from 2008 and appreciate the different set of rules that would apply.
I wonder if any of the members had to deal with similar situation or would have any observations?
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