The residency and domicile status of an individual determines their exposure to UK direct taxes (namely income tax, capital gains tax and inheritance tax).

An individual has access to a favourable UK tax regime, known as the “remittance basis” of taxation, even if they become resident in the UK, if they remain domiciled outside the UK.

An individual who is UK resident, but non-UK domiciled can either be taxed on the arising basis or the remittance basis. The arising basis means that an individual will be taxed in the UK on their worldwide income and gains in the tax year in which the income or gain arises regardless of whether the funds are brought to the UK. If an individual claims the remittance basis of taxation, they should not have to pay inheritance tax or capital gains tax on non-UK income and non-UK capital gains so long as they are remitted to the UK.

Given the beneficial remittance basis of UK taxation available to non-UK domiciled individuals who are UK tax resident, it is important that clients wishing to move to the UK or send family members to live in the UK, take expert pre-arrival planning advice before moving.

Briefing Note: Becoming Deemed Domiciled

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