We have a client, who was thought to be non UK domiciled (although would have been deemed domiciled in recent years).
We now doubt his non UK domicile status - dating back circa 10 years.
Client is settlor of a non UK resident Trust, and beneficiary and since 2015 has received substantial payments from the Trust.
The Trust owns a Non UK company (holds a portfolio) and a loan to that company. The loan has been partially repaid to the Trust, thereby allowing the capital payments to the settlor/beneficiary.
In terms of the very limited Trust income, s624 will apply.
In terms of the company income:
s720 - could only apply from the point that he was UK domiciled.
s731 - would apply from the point that the capital payment was made to him (does it matter that its from the Trust not the company?)
We will have a situation whereby he is due to be taxed on current year s720 income, and at the same time s731 on historic company income - ie before s720 came into effect because of his change in domicile status. Does this sound correct?