Why Domicile Matters
A domicile of origin has been described as having a strong adhesive quality and is difficult to lose in favour of a domicile of choice. With the burden of proof resting on the party alleging the change, if you came to the UK with a domicile of origin outside of the UK and have the intention of leaving the UK, you can be confident of being a resident foreign domiciliary for tax purposes in the UK. You can then consider being taxed as a remittance basis user whereby only your non-UK source income and gains to the extent remitted to the UK are taxable in the UK.
At Ritchie Phillips, we have considerable experience of negotiating an individual’s domicile status including first hand experience of dealing with the most senior officers of HM Revenue and Customs.