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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 general law. The rules apply for income tax, capital gains tax (CGT) and inheritance tax (IHT). However, see ‘Changes expected from 2025/26’ below.

Although the tests are slightly different for IHT compared to income tax and CGT (see below), broadly an individual is deemed UK domiciled if they:

1. •

   have been 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 becomes resident in the UK

The 20-year ‘look-back’ period for 2023/24 (for example) is 2003/04 to 2022/23. The ‘clock’ does not start from 2017/18.

Where an individual is deemed domiciled for income tax and CGT, they are taxable in the