Residence of individuals

The tax residence of an individual has long been relevant in determining liability to income tax and capital gains tax (CGT). As is explained in Practice Note: Introductory guide to residence and domicile for UK tax purposes before 6 April 2025 [ARCHIVED], those resident in the UK are taxable on their worldwide income and gains. Non-residents, by contrast, are taxable only on certain sources of UK income, and their capital gains are in general free from tax.

Before 6 April 2025, tax residence was not relevant to inheritance tax (IHT); rather, domicile was the key factor determining liability to IHT—see Practice Note: Domicile for UK tax purposes before 6 April 2025 [Archived] However, since 6 April 2025, liability to IHT is based on residence in the UK. For more information, see Practice Note: A new residence-based regime for IHT from 2025–26

Prior to 6 April 2013, ordinary residence applied as a distinct concept from residence and domicile for UK tax purposes. The concept of ordinary residence was removed and replaced with references to residence from 6 April 2013. But under transitional rules, ordinary residence