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New proposal

06 October 2015 / Malcolm Finney
Issue: 4521 / Categories: Comment & Analysis

HMRC’s recently published proposals for the introduction of a deemed UK domicile status.


  • HMRC release follow-up consultation on non-domiciles.
  • Proposals seem likely to come into effect from 6 April 2017.
  • Deemed domicile status will mean the end of the remittance basis for foreign income and gains.
  • The £90 000 remittance basis charge will end.
  • Non-domiciles who were UK-domiciled before they moved abroad will be treated as UK domiciled immediately upon their return to this country.
  • Some taxpayers should consider whether to become non-UK resident for a time to avoid deemed domicile status.

In his summer Budget George Osborne announced that those non-UK domiciled but UK resident individuals who resided in the UK for more than 15 of the past 20 tax years were to be treated as deemed UK domiciled for all (not just...

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