RDRM22250 - Domicile: Categories of domicile: Domicile of dependence - Married Women after 1 January 1974
From 6 April 2025, the concept of domicile as a relevant connecting factor in the tax system has been replaced by a system based on tax residence. This guidance remains for reference purposes only.
For marriages that took place prior to 1 January 1974, Section 4 of the DMPA 1973 effectively re-imposed the wife바카라 사이트™s domicile of dependence at 31 December 1973 as a domicile of choice capable of being lost in the same way as any other domicile of choice. Section 4 DMPA 1973 applies in all parts of the UK.
For marriages that have taken place on or after 1 January 1974 a woman바카라 사이트™s domicile is unaffected by the marriage itself. The marriage nonetheless forms part of the evidence relevant to ascertaining a woman바카라 사이트™s domicile.
Women who are US nationals
Article 4(4) of the UK/USA Double Taxation Convention (DTC) deals with the domicile of a US national married, prior to 1 January 1974, to a man domiciled within the UK. When determining the wife바카라 사이트™s domicile for UK tax purposes, on or after the date on which the DTC first had effect in relation to her, the marriage is deemed to have taken place on 1 January 1974.
This position is unaffected by the ending of the marriage, for whatever reason, prior to 1 January 1974.
In practice this means that a woman who is a US national will be treated for UK tax purposes as never having had a domicile of dependence derived from a husband domiciled in any part of the UK. The DTC does not affect the factors relevant to determining such a woman바카라 사이트™s domicile of choice prior to 1 January 1974.