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Home / Simons-Taxes /Personal and employment tax /Part E6 Overseas issues /Division E6.3 Domicile and the remittance basis /Deemed domicile for income tax and capital gains tax / E6.323C Deemed domicile—rebasing for capital gains tax (2017/18 onwards)
Commentary

E6.323C Deemed domicile—rebasing for capital gains tax (2017/18 onwards)

Personal and employment tax

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

Capital gains tax applies to the worldwide assets of an individual who is deemed to be UK domiciled after 5 April 2017, so that gains arising on those assets are normally within the UK CGT charge regardless of where the asset is situated (see C1.102). The remittance basis at E6.324A onwards does not generally apply to gains arising in a tax year of deemed domicile on foreign-situs assets. Remittance basis foreign gains of any year are taxable in the tax year in which they are remitted to the UK, regardless of the fact that the individual's status may have altered for the year of remittance to deemed domicile (so that the remittance basis does not apply to gains in a tax year of deemed domicile).

Certain non-domiciled individuals who became deemed UK-domiciled on 6 April 2017 automatically have the capital gains tax base cost of the foreign assets that they held at 5 April 2017 rebased to their market value at that date1.

Note

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