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Law firm Boodle Hatfield has slammed the new rules relating to the tax treatment of UK resident non domiciliaries for being uncertain and an administrative burden.

Hayden Bailey, a tax planning expert and solicitor for Boodle Hatfield, said: "We now have a set of complicated rules that make it essential for those affected to seek professional advice. There is plenty of opportunity to make mistakes and clients’ record keeping will need to be immaculate."

Boodles Hatfield notes that the much debated £30,000 charge to be levied on non-doms is still there, despite the concession in the Budget that it would be treated as tax paid.

Hayden does not believe that the concession will be as much of a benefit as originally envisaged: "When we actually get to the detail of the legislation itself, there are complex rules requiring non doms to nominate which income and gains the £30K charge is to apply to. If this is later brought to the UK, there is no further UK tax to pay.

"But if there is other unremitted foreign income or gains this is deemed to be remitted first. The result is that the £30,000 is only credited as tax paid after you have brought in all other income and gains for the tax year. Because non doms will not necessarily remit all of their income and gains each year, the £30,000 payment may still have the feel of a stand alone annual charge."

Hayden also highlights how the rule change may cause confusion with regard to the treatment of assets purchased overseas and brought into the UK.

From 5 April, any asset derived from offshore income or gains, such as works of art or cars will be liable to a tax charge when brought into the UK, but not in all cases, as he explains: "There are some exception such as assets in the UK for repair or restoration, located in the UK on a temporary basis, which is considered 275 days or less, or which meet public access rules such as works of art in a museum.

"However the rules are going to be interesting to work through in practice. It seems that a yacht bought out of foreign income and gains will now become liable to tax if it stays in UK waters for over 275 days. But what if the yacht then needs repairing? What counts as a repair? The legislation seems far from watertight."