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Introduction

Before 6 April 2025, domicile was one of the key factors to consider when deciding whether, or to what extent, an individual was liable to tax in the UK. The other is residence, see the Residence ― overview guidance note. As mentioned below, non-domiciliaries were able to use the remittance basis of taxation in the UK, which meant that their foreign income and gains were not taxable in the UK unless they are brought to the UK.

The concept of domicile is abolished for tax purposes from 6 April 2025 onwards. Instead, from that date liability to tax is based on system that depends on an individual’s UK residence pattern. For a summary of the rules that apply to income tax and capital gains from 6 April 2025, including the transitional rules, see the Abolition of the remittance basis from 2025/26 guidance note. For a summary of the rules that apply to inheritance tax from 6 April 2025, see paras 146–235 of the HMRC technical paper.

This guidance note explains the concept of domicile, why it mattered, how it