Non-UK Domicile Status

Statutory Residence Test

• Automatic overseas residence
• Automatic UK residence
• ‘Sufficient ties’ tests
• Split-year treatment
• Including case study
• Temporary non-residence

Domicile status

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

Key tax issues

• Overview of impact of residence and domicile status for income tax, CGT and inheritance tax (IHT).
• Situs (location) of assets
• Remittance basis for non-doms
  • 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 (No.2) Act 2023 anti-avoidance concerning share exchanges in close companies

Deemed domicile status

• Long-term residents
• Formerly domiciled residents

Impact of deemed domicile status, including

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

March 2024 Budget

• Abolition of remittance basis from April 2025
• Key points of the proposed replacement ‘foreign income and gains’ (FIG) regime
• Transitional provisions, including rebasing of assets for CGT purposes
• Proposed new IHT regime, based on residence rather than domicile status

Our non-domicile status 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 writes regularly for Tax Insider and speaks at conferences of bodies such as the ICAEW and CIOT.

This non-UK domicile status course explains to delegates the key UK tax implications of being non-UK domiciled. In addition, we discuss how residence and domicile status are determined. The course is aimed at non-specialists so will not cover advanced planning, but will explain the key issues resulting from the proposed reforms announced in the March 2024 Budget.

• Redcliffe’s non-UK domicile status course trainer is a Chartered Accountant with over 30 years’ experience in tax training
• Key cases will be covered
• Many practical scenarios will be discussed
• Several short case studies are included
• The major reforms announced in the March 2024 Budget will be explained

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

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

We will finish by looking at the proposals for fundamental reform announced in March 2024, including the abolition of remittance basis from April 2025 and a new IHT regime, based on residence rather than domicile.

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