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