Non-UK Domicile Status

This course will explain to delegates the key UK non-dom tax implications of being non-UK domiciled, as well as discuss how residence and non-domicile status in the UK are determined. It is aimed at non-specialists so it will not cover advanced planning.

UK Tax Statutory Residence Test

• Automatic overseas residence
• Automatic UK residence test
• ‘Sufficient ties’ tests
• Split-year tax treatment
  • Case study
• Temporary non-residence rules income test

Domicile status

• Domicile of origin
• Domicile of dependency
• UK Domicile of choice
• Changing one’s domicile status
  • How to do it
  • Key cases

Key tax issues

• Overview of the impact of residence and domicile status for income tax, CGT and inheritance tax (IHT).
• Situs (location) of assets
• Remittance basis for non-doms status
  • Remittance basis charge
  • Availability of allowances
  • Case study
• ‘Mixed’ bank accounts
• Excluded property trusts
• IHT rules for mixed domicile spouses / civil partners
• How all UK residential property now potentially falls within the IHT net
• Finance Bill 2023 anti-avoidance concerning share exchanges in close companies

Deemed domicile UK status

• Long-term UK resident non domiciled
• Formerly domiciled residents 

Impact of deemed domicile in the UK status, including

• Loss of remittance basis
• Option to rebase assets to April 2017 values for CGT 

Double tax relief

• Foreign tax credit relief UK
• Special withholding taxes

Our trainer is a Chartered Accountant who qualified with PwC in 1988, spending his last 18 months there in the Tax department. In 1989 he joined a leading financial training company as a tax tutor. Since 1992, he has been self-employed as a Professional Tutor and Training Consultant, specialising in tax update courses for accountants, lawyers and investment managers.

Our trainer has been teaching in the financial services industry since 1994 and writes regularly for Tax Insider.

Establishing someone's domicile status is often not straightforward, as it can involve knowing a lot about their past and future intentions. In addition, specific non-UK individuals can be treated as "deemed UK domiciled" for tax purposes.

This course will assume no prior knowledge of the topic. After outlining how an individual's UK residence status is established, we will discuss, concerning cases, how an individual's domicile is determined. We will then explain the critical tax impacts of non-UK domiciled individuals tax status and deemed UK domicile tax status, including matters such as remittance basis, the problems with 'mixed' bank accounts and special inheritance tax rules that apply for mixed domicile marriages.

Finally, we will briefly examine how relief for foreign taxes is given in the UK.

Note that only UK tax residency rules will be discussed, not the tax law in other jurisdictions.