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Introduction

This note is an outline of many complex issues. It summaries the position and indicates which guidance notes will provide further information.

The starting point is that UK tax liability depends on two key factors:

1. •

   residence

2. •

   domicile

Residence refers to the individual’s tax status on a year by year basis. Domicile is the place which a person regards as his true home.

Up until 5 April 2013, a taxpayer’s ordinary residence status was the third key factor. Ordinary residence arises as a result of a settled purpose and so looks at the position over the longer term. The concept