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Deemed domicile from 6 April 2017

A person not otherwise domiciled in the UK under the general law may be deemed to be domiciled for tax purposes. The concept of deemed domicile for income tax (IT) and capital gains tax (CGT) was introduced with effect from 6 April 2017. See the Deemed domicile for income tax and capital gains tax (2017/18 onwards) guidance note in the Personal Tax module. At the same time, the long-standing inheritance tax rule for deemed domicile, based on 17 out of 20 years’ residence in the UK, was amended.

There are now three separate rules that can apply deemed domiciled status for inheritance tax purposes, as follows:

1. •

   the person was domiciled in the UK under general law at any point in the last three years

2. •

   the person is a ‘formerly domiciled resident (FDR)’ (see below)