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For unremitted income and gains earned prior to 6 April 2025, the following is still relevant as the changes after 6 April 2025 only impact earnings and gains after this date. This is subject to the option to use the temporary repatriation facility (TRF) for previously unremitted gains (see UK1.2.4)

Domicile is a legal concept and does not have a specific definition for tax purposes. It is often defined as the place where a person has their permanent home. As such it contains two elements: a person's home and the intention of remaining there permanently.

Domicile is normally tied to a territory subject to a single system of law, so an individual may be domiciled in England and Wales, or in Scotland, or in Northern Ireland, but not in the UK. It is not the same as nationality. However, for the sake of simplicity those domiciled in the home nations of the UK are called 'UK domiciled'.

There are three types of domicile:

1. Ìý

   •ÌýÌýÌýÌý domicile of origin

2. Ìý

   •ÌýÌýÌýÌý domicile of