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

Married couple’s allowance

Married couple’s allowanceThe married couple’s allowance (MCA) is only available if one of the two spouses or civil partners was born before 6 April 1935. This means that one member of the couple must be at least 89 years old on 5 April 2024 to qualify for an allowance in the 2023/24 tax year.There

14 Jul 2020 12:13 | Produced by Tolley Read more Read more

Self assessment ― amendments and corrections

Self assessment ― amendments and correctionsOnce a self assessment tax return has been filed, both HMRC and the taxpayer (or the agent) has the right to make changes to the return. There are different time limits depending on whether it is a correction by HMRC or an amendment made by the

14 Jul 2020 13:37 | Produced by Tolley Read more Read more

Fuel-related payments / mileage payments

Fuel-related payments / mileage paymentsIntroductionMost employers will make payments to employees in relation to business travel. Among the most common payments in relation to business travel are fuel and mileage payments. If an employer does not reimburse these amounts, then the employee will be

14 Jul 2020 11:46 | Produced by Tolley in association with Philip Rutherford Read more Read more