Deemed domicile ― rebasing for capital gains tax

Produced by a Tolley Personal Tax expert
Personal Tax
Guidance

Deemed domicile ― rebasing for capital gains tax

Produced by a Tolley Personal Tax expert
Personal Tax
Guidance
imgtext

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, capital gains tax (CGT) and inheritance tax (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

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+
  • 30 Jul 2026 10:10

Popular Articles

Outright gifts

Outright giftsAn outright gift is the most straightforward type of gift. It simply involves the outright transfer of property from one person to another with no conditions attached.This type of gift is most suitable for clients who want to pass over modest amounts, or give to responsible and capable

14 Jul 2020 12:22 | Produced by Tolley in association with Emma Haley at Boodle Hatfield LLP Read more Read more

Incentives, awards and prizes

Incentives, awards and prizesIntroduction ― incentives, awards and prizesEmployers may use a variety of methods to reward and encourage employees in their work. These are commonly known as incentives, awards or prizes. For the purposes of this note, the term ‘award’ will be used to cover all

14 Jul 2020 11:57 | Produced by Tolley Read more Read more

Non-business expenses

Non-business expensesIntroductionIn order for an expense to be tax deductible it must be incurred because of an employee’s employment. Any non-business related expense is, therefore, not relievable except in some very particular circumstances.This guidance note deals with three separate issues. The

14 Jul 2020 12:16 | Produced by Tolley Read more Read more