UK private client tax experts have long pointed out that if the UK government wanted to attack non-doms they could do so by simply changing small areas of legislation, burying the changes amongst other announcements and claiming the changes are just a "tightening of the rules". According to Richard Jordan, private client partner at law firm Stevens & Bolton, the government plans to do exactly that. Mr Jordan points to page 42 of 66 of the pre-budget report notes. In paragraph 12 "Anomalies" the Treasury says changes will be made to "reduce the scope for alienation of income and gains through offshore structures converting them into non-taxable payments". Mr Jordan told WealthBriefing this means "UK resident and non-domiciled persons will no longer be able to use offshore trusts to mitigate income and capital gains tax". “This is a massive attack on non-doms and their investment in the UK,” he said. “Forget the £30,000 levy, that is unlikely to prove more than a minor inconvenience. This amendment will change the basis upon which almost every non-dom individual plans their affairs.” For non-doms, the standard set up is to keep income offshore, but bring in the trust capital and gains tax free, to spend in the UK. This would be ended if Mr Jordan’s interpretation of the small print is correct and ends up in the legislation. But under the proposals, non-doms’ foreign income and gains remains untaxed, although they will not be able to bring that into the UK in any circumstances without taxation. That means they have to live off taxed UK income or gains, or plain capital cash offshore, which severely restricts investment opportunities. As the proposals stand, non-doms will no longer be able to invest in the UK without paying capital gains tax when the asset is sold, says Mr Jordan. This will lead to a large drop in investment in the UK property market in particular. And non-doms may find it hard to maintain their lifestyles in the UK without bringing in money from abroad which would likely lead to a tax charge. “Switzerland should be prepared for a large surge of Permit B applications from non-doms looking to set up base their under the "forfait arrangement," said Mr Jordan.