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Deemed domicile for income tax and capital gains tax

For the latest New Developments, see ND.2620 and ND.2751.

Legislation in F(No 2)A 2017¹ introduced the concept of deemed UK domicile for income tax and capital gains tax purposes with effect from 6 April 2017, and changed the deemed domicile legislation for inheritance tax purposes (see I9.206) from the same date. The tests for deemed domicile for income tax and capital gains tax and the tests for deemed domicile for inheritance tax are similar but not the same. There is also an extra test for inheritance tax that is not included in the income tax and capital gains tax provisions. It is important to check both provisions because the individual may be UK deemed domiciled under one set but not the other. See also 'Double tax treaties for inheritance tax – impact on income tax and capital gains tax' below.

These changes affect income and capital gains accruing after 5 April 2017 (including certain income and gains of