TSEM4715 - Settlements Legislation: Rules affecting non-domiciled and deemed domiciled settlors of non-resident trusts from 6 April 2025: Tainting
From 6 April 2025, the protection offered to offshore trusts and structures settled by non-UK domiciled settlors or those deemed domiciled under condition B have been removed. From this date, all UK resident settlors will be taxed on the arising basis in the same way. This removes the concept of tainting from the legislation as all income will be taxable on a UK resident settlor when the requirements of section 624, section 629, or section 633 ITTOIA 2005 are met. Section 628B ITTOIA 2005 has been removed to reflect this.