Changes to UK’s Deemed Domicile Provisions

From the start of the new UK tax year – ie from the 6th of April, 2017 – significant changes affect non-UK domiciled individuals, with the introduction of new deemed UK domicile rules for individuals who have been UK resident for more than 15 of the previous 20 years.

Part tax years and split tax years will be treated as years of residence for this test.

The existing deemed UK domicile rules apply to individuals who have been resident in the UK for 17 of the previous 20 years and attach only to inheritance tax ; the new rules will be extended to include income tax and capital gains tax.

Any who are covered by the new deemed UK domicile rules will have to report their worldwide income and gains to HM Revenue in the UK on an arising basis.

A new concept of a returning UK domiciliary is also being introduced.

Individuals who were born in the UK and who had a UK domicile of origin will be classified as a returning UK domiciliary under the proposed rules.

Non-UK-domiciled individuals who will have been UK resident for more than 15 of the previous 20 years on the 6th of April, 2017 should consider their position as soon as possible.

Ditto for those who had a domicile of origin in the UK, who have acquired a non-UK domicile of choice after spending a number of years away from the UK, and who will be resuming tax residence in the UK on or after the 6th of April, 2017.

We invite any who are concerned about their UK tax position to complete the enquiry form on this page for a free initial discussion.