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

Special rate pool and long life assets

Special rate pool and long life assetsSpecial rate poolExpenditure on some types of plant or machinery must, if neither annual investment allowance (AIA) nor first year allowances (FYAs) are available, be allocated to a ‘special rate pool’. Expenditure to be allocated to the special rate pool

14 Jul 2020 13:41 | Produced by Tolley Read more Read more

Reverse charge ― buying in services from outside the UK

Reverse charge ― buying in services from outside the UKThis guidance note covers the reverse charge that applies to services that have been bought in from outside the UK. For an overview of VAT and international services more broadly, see the International services ― overview guidance note. For

15 Dec 2020 14:02 | Produced by Tolley Read more Read more

Payments on account (POA)

Payments on account (POA)This guidance note provides and overview of the payments on account regime (POA). More in depth commentary can be found in De Voil Indirect Tax Service V5.110.What are payments on account?VAT registered businesses with an annual VAT liability of more than £2.3m are required

14 Jul 2020 12:52 | Produced by Tolley Read more Read more