Domicile of individuals

Q&As

Will a UK citizen who has not been resident or domiciled in the UK for over ten years fall under the non-domicile rules for inheritance tax (IHT) purposes?

Will a UK citizen who has not been resident or domiciled in the UK for over ten years fall under the non-domicile rules for inheritance tax (IHT)...

31st Jul

Q&As

An individual (not domiciled in the UK) makes a gift of UK property to an individual who is resident in the UK. The donor retains a benefit in that gift. The donor then becomes domiciled in the UK. Do the gifts with reservation rules apply and therefore, would the gifted property fall within the donor's estate?

An individual (not domiciled in the UK) makes a gift of UK property to an individual who is resident in the UK. The donor retains a benefit in that...

31st Jul

Q&As

Is there a special rule which means that a British ambassador is deemed to be resident and/or domiciled in the UK for tax purposes, even if he/she is living for the time being in the country to which he/she has been sent?

Is there a special rule which means that a British ambassador is deemed to be resident and/or domiciled in the UK for tax purposes, even if he/she is...

31st Jul

Practice notes

Domicile and habitual residence

Domicile and habitual residence11pm (GMT) on 31 December 2020 marked the end of the Brexit transition/implementation period entered into following the...

Produced in partnership with David Salter of Deputy High Court judge and Recorder 31st Jul

In-house

Practice notes

Planning for becoming deemed domiciled under the 15-year rule

Planning for becoming deemed domiciled under the 15-year ruleFinance (No 2) Act 2017 (F(No 2)A 2017) introduced several tax reforms in relation to...

31st Jul

Practice notes

Domicile

DomicileThe concepts of domicile and residence are used to establish the extent of an individual’s liability to UK taxation. Specifically, domicile...

31st Jul

Practice notes

Mixed domicile spouses and civil partners

Mixed domicile spouses and civil partnersSection 18 of the Inheritance Tax Act 1984 (IHTA 1984) contains an unlimited exemption from inheritance tax...

31st Jul

Practice notes

Glossary of UK trust and taxation law terms for international clients

Glossary of UK trust and taxation law terms for international clientsAAdministrationThe process starting on the date of the deceased's death and...

31st Jul

Practice notes

Introductory guide to residence and domicile for UK tax purposes

Introductory guide to residence and domicile for UK tax purposesThe concepts of residence and domicile are used to establish the extent of an...

31st Jul

Practice notes

Domicile of individuals Q&As

Domicile of individuals Q&AsFor general information on domicile, see: Domicile of individuals—overview.Note that although new Q&As are added to this...

31st Jul

Practice notes

Deemed domicile for tax before 6 April 2017 [Archived]

Deemed domicile for tax before 6 April 2017 [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.The incidence of...

31st Jul

Practice notes

Deemed domicile for tax from 6 April 2017

Deemed domicile for tax from 6 April 2017At Summer Budget 2015, the government announced wide-ranging reforms to the deemed domicile rules and also to...

31st Jul

Precedents

Domicile and deemed domicile—client guide

Domicile and deemed domicile—client guideKey points•domicile is a legal status which links an individual to the laws of a particular jurisdiction—it...

30th Jul

Q&As

X intends to obtain counsel’s opinion on whether X is deemed domiciled in the UK in the current tax year. To what extent would getting such an opinion mitigate any penalties that may apply as a result of counsel advising that X actually acquired a deemed domicile in an earlier tax year?

X intends to obtain counsel’s opinion on whether X is deemed domiciled in the UK in the current tax year. To what extent would getting such an opinion...

6th Jun

Q&As

Does an individual in the military service of the Crown retain his English common law domicile if he is sent on duty to a non-UK territory?

Does an individual in the military service of the Crown retain his English common law domicile if he is sent on duty to a non-UK territory?The...

5th Jun

Q&As

To what extent can the estate of a non-UK domiciled person (A) who has UK-situs assets on death, claim any unused portion of the nil rate band of A’s deceased spouse, B, where B, on death, was non-UK domiciled, and did not have any UK-situs assets?

To what extent can the estate of a non-UK domiciled person (A) who has UK-situs assets on death, claim any unused portion of the nil rate band of A’s...

5th Jun

Q&As

What are the inheritance tax rules concerning lifetime and testamentary gifts between UK and non-UK domiciled individuals?

What are the inheritance tax rules concerning lifetime and testamentary gifts between UK and non-UK domiciled individuals?The main point to appreciate...

5th Jun

Q&As

A child with a non-UK domicile of origin in Country A moves to the UK with their parents and acquires a UK domicile of dependency. If the child leaves the UK after the age of 16 to live in Country B, what domicile would they have? What is the position if they later return to the UK?

A child with a non-UK domicile of origin in Country A moves to the UK with their parents and acquires a UK domicile of dependency. If the child leaves...

5th Jun

Q&As

If a non-domiciled spouse is making a domicile election following the death of their UK domiciled spouse for the seven-year period before the deceased's death up to the point of the deceased's death, does it make any material difference if the non-domiciled spouse does not live in the UK at the time or does not have immigration rights to live in the UK?

If a non-domiciled spouse is making a domicile election following the death of their UK domiciled spouse for the seven-year period before the...

5th Jun

Q&As

If an individual is deemed domiciled for all tax purposes as a result of the changes in the second Finance Bill 2017, are they eligible for business investment relief?

If an individual is deemed domiciled for all tax purposes as a result of the changes in the second Finance Bill 2017, are they eligible for business...

5th Jun

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