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Introduction

Fundamental changes to the tax regime for non-domiciled individuals were introduced from 6 April 2017. They involve deeming an individual to be UK domiciled for tax purposes even though they may be non-domiciled in the UK under common law. The rules apply for income tax, capital gains tax (CGT) and inheritance tax (IHT). The rules are in force for tax years 2017/18 to 2024/25 inclusive. The concept of domicile and deemed domicile were abolished from 6 April 2025. See ‘Abolition of the concept of domicile and deemed domicile from 6 April 2025’ below.

Although the tests are slightly different for IHT compared to income tax and CGT (see below), broadly an individual is deemed UK domiciled for a tax year between 2017/18 to 2024/25 if they:

1. •

   were UK resident for at least 15 out of the last 20 tax years, or

2. •

   were born in the UK with a UK domicile of origin, subsequently left the UK and acquired a non-UK domicile of choice and later became resident