Abolition of Domicile as as a UK tax-connecting factor

The Government has proposed to end the use of domicile as a determinant of tax liability for individuals from 6 April 2025. The remittance basis of taxation will also end. This brings to an end an aspect of the UK’s international tax system that started when income tax was introduced in 1799, and that has formed a central pillar of the UK tax system that attracted individuals to the UK.

The legal concept of domicile for income tax, capital gains tax and inheritance tax is to be superseded by a series of rules that rely on tax residence to provide a measure of relief for internationally mobile individuals. A summary noite has been added to the home page of Booth and Schwarz: Residence, Domicile and UK Taxation