The following Private Client practice note provides comprehensive and up to date legal information covering:

  • Domicile
  • What is domicile?
  • General principles of domicile
  • Domicile of origin
  • Domicile of dependency
  • Children
  • Married women
  • Domicile of choice
  • Acquisition and loss of domicile
  • Demonstrating a change in domicile to HMRC
  • More...


The concepts of domicile and residence are used to establish the extent of an individual’s liability to UK taxation. Specifically, domicile determines an individual’s liability to UK inheritance tax (IHT) on foreign situs assets and is a key factor in establishing whether the remittance basis could be applicable to the taxation of foreign income and gains. See the Introductory guide to residence and domicile for UK tax purposes Practice Note for guidance on the tax implications of residence and domicile.

The definition of domicile in the context of UK taxation is taken from its ordinary meaning and case law, rather than being set out in statute. Domicile is a concept separate from nationality, residence or citizenship and the outcome is determined by applying a set of principles to the individual’s circumstances. An element of permanence and intention are fundamental in ascertaining domicile.

The place in which an individual is domiciled is not necessarily a country but any jurisdiction governed by a single system of law. For example, an individual will not be domiciled in the UK but in England and Wales, Scotland or Northern Ireland. However, in this Practice Note the term ‘UK domicile’ is used for ease of reference.

HMRC Guidance Note: Residence, Domicile and the Remittance Basis (RDR1) provides basic information on the meaning of domicile from 6 April 2013 onwards.

The previous HMRC Guidance Note

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