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
  • Including case study
• IHT rules for mixed domicile spouses / civil partners
• How all UK residential property now potentially falls within the IHT net 

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 

Double tax relief

• Foreign tax credit relief
• Special withholding taxes

The trainer is a Chartered Accountant who qualified with PwC in 1988, spending his last 18 months there in the Corporate Tax department.

In 1989 he joined a leading financial training company as a tax tutor, teaching final level candidates for the ICAEW and ACCA examinations. 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.

He has been teaching in the financial services industry since 1994. Although he concentrates on the professional development market these days, he is very experienced in teaching stock brokers, fund managers and financial advisors for their various regulatory examinations.

As a result, he is a tax specialist with (unusually) a very rounded knowledge of financial services products and markets. In 2012 this led to him undertaking Gapfill courses for the CISI.

He is a regular contributor to Taxation magazine and speaks at regional conferences of the ICAEW and CIOT.

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 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.

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

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