Introduction

Under rules that applied between 2017/18 and 2024/25 inclusive, individuals were deemed to be UK domiciled for tax purposes even though they have been non-domiciled in the UK under common law. The rules applied for income tax, CGT and IHT.

Non-domiciliaries:

1. •

   caught by the deemed domicile 15-year rule from 2017/18 may be able to rebase their foreign chargeable assets for CGT purposes as at 5 April 2017

2. •

   had a one-off opportunity to clean up existing mixed funds, see the Remittance basis ― until 5 April 2025 guidance note

Whilst both these measures were good news for the non-domiciliary, they were not available for all non-domiciliaries and the rules contained traps for the unwary.

This guidance note explores rebasing for CGT in detail. For a discussion of the broader rules as they apply to individuals, including the IHT changes, see the Deemed domicile for income tax and capital gains tax (2017/18 to 2024/25) guidance note. You are recommended to read that guidance note before continuing.

Note that the professional