RDRM23020 - Domicile: Enquiries into domicile status: Change of domicile
From 6 April 2025, the concept of domicile as a relevant connecting factor in the tax system has been replaced by a system based on tax residence.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.
As an individual바카라 사이트™s circumstances change so can an individual바카라 사이트™s domicile, which means that a person바카라 사이트™s operative domicile today might not be the same as his or her operative domicile as a child, and that the individual바카라 사이트™s operative domicile in future might be different again.
An individual바카라 사이트™s 바카라 사이트˜operative domicile바카라 사이트™ is the domicile that the laws of the UK would regard as applying to that person at the 바카라 사이트˜relevant time바카라 사이트™. For UK tax purposes this might, for example, be the time at which the individual made a capital gain on assets located outside the UK or the date when he or she made a lifetime transfer to a settlement.
The laws of the UK make it clear that domicile is not easily changed, and so it is unlikely that an adult바카라 사이트˜s operative domicile will alter unless the individual makes profound and extensive changes to his or her lifestyle, habits and intentions. A change in an individual바카라 사이트™s operative domicile is never to be assumed, it always has to be demonstrated by reference to the facts.
Domicile is a personal matter. During the course of any enquiry in this area personal information will have to be obtained and reviewed. In more complex cases the nature and extent of such information can be extremely wide ranging, deeply personal, time-consuming to provide and involve not only the individual but also family and close friends.
Not only is domicile a personal matter, it is also one that potentially has consequences apart from any effect it has upon an individual바카라 사이트™s tax liability in the UK. These consequences could affect other people, particularly any children of the individual.
An individual can only have one domicile at any one time for the same purpose. So HMRC would not expect an individual to assert a common law domicile for a specific purpose which the person would not wish to apply more generally to his or her affairs. HMRC will consider statements made about domicile and an individual바카라 사이트™s intentions that are provided for purposes such as immigration and nationality, marriage and the care of children.
Although information given to HMRC is treated as confidential, the UK courts can order HMRC to produce it.