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STOP PRESS: The remittance basis is to be abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in Finance Bill 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

Individuals should consider whether to undertake any tax planning before becoming UK deemed domiciled for income tax, capital gains tax (CGT) and / or inheritance tax (IHT) purposes.

This guidance note summarises the deemed domicile tests, the impact of becoming deemed domiciled on an individual’s tax position and some general tax planning that may be appropriate depending on the individual’s circumstances.

The tax issues discussed below are complex and the commentary is only intended to be an overview. Specialist advice based on the individual’s circumstances may be necessary.

When considering the commentary below, bear in mind that changes to the taxation of foreign domiciliaries were announced in Spring