Remittance Basis and Domicile Manual

RDRM25070 - Domicile: Deemed domicile: Leaving the UK prior to 6 April 2017

From 6 April 2025, the concept of domicile as a relevant connecting factor in the tax system has been replaced by a system based on tax residence.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.

Condition B will not be met if:

• an individual is not UK resident for the relevant tax year
• there is no tax year beginning after 5 April 2017 and preceding the relevant tax year in which the individual was UK resident.

Example

Maria was born in Italy and had an Italian domicile of origin. She came to the UK to work in 1996 and remained for 20 years. It has always been her intention to return to Italy to settle permanently. Therefore, for UK tax purposes she considers she is resident but not UK domiciled.

In August 2016 she returns to Italy to care for her widowed mother. Although she has been resident in the UK for 20 years, Maria will not be deemed domiciled in the UK as she ceased to be UK resident prior to the start of the 2017-2018 tax year, the first year these new rules come into force.

If Maria retuned to the UK and became resident again after April 2017, she would have to review the last 20 years to work out if she is deemed UK domiciled.