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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, CGT and IHT.

Non-domiciliaries:

1. •

   caught by the deemed domicile 15-year rule in 2017/18 may be able to rebase their foreign chargeable assets for CGT purposes as at 5 April 2017

2. •

   had a one-off opportunity to clean up existing mixed funds, see the Remittance basis ― mixed fund cleansing (April 2017 to April 2019) guidance note

Whilst both these measures were good news for the non-domiciliary, they were not available for all non-domiciliaries and the rules contained traps for the unwary.

This guidance note explores rebasing for CGT in detail. For a discussion of the broader rules as they apply to individuals, including the IHT changes, see the Deemed domicile for income tax and capital gains tax (2017/18 to 2024/25) guidance note.