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Scrapping Non Domiciled Status April 2025
In Law, domicile is relevant to an individual’s “personal law”, which includes the law that governs a person’s status and their property, It is independent of a person’s nationality.
Although a domicile may change from time to time, a person has only one domicile, or residence, at any point in their life, no matter what their circumstances. Domicile is distinct from a habitual residence, where there is less focus on future intent.
A lot of individuals don’t appreciate that the UK has a unique way of assessing people to tax, that outside of their control
It is, where you and your father were born that can create domicile of origin which is difficult to shake off to domicile of choice.
So by scrapping the non domiciled the Chancellor is actually taking away a number of opportunities to reduce worldwide tax to people that live internationally.
I have spoken to over 200 tax payers in Hong Kong ,who were considering moving to the UK under the BNO visa options. A high proportion have serious wealth and chose to come to the UK and by exercising Non Dom status they saved a considerable of tax that otherwise would have been payable.
The rules are set to change and one thing the budget is not law until the finance bill is passed by parliament there are usually no upsets.
What become more important are the Residency test and the Ties if the Non Dom as the non dom is crapped it will more important to establish what the implications of staying too long in the UK
I have number of client who live and work in Dubai, whether for an employer or have setup their own business and work remotely throughout the world, the residency rules and the number of ties they retain to the UK become very important.
Most countries have double tax agreements with UK but a number don’t this can cause big issues and setting up the structure to pay the right amount to the right jurisdiction. Telling HMRC you have left the UK is one of the steps.
Also we are licensed probate professional and advise where the partners and spouses are non doms , very often this is not appreciated that they end up not having the same rights as dom spouse.
Andrew Davis
UK and International Tax Specialist
