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Introduction

Before 6 April 2025, domicile was one of the key factors to consider when deciding whether, or to what extent, an individual was liable to tax in the UK. The other is residence, see the Residence ― overview guidance note. As mentioned below, non-domiciliaries were able to use the remittance basis of taxation in the UK, which meant that their foreign income and gains were not taxable in the UK unless they are brought to the UK.

Although domicile is no longer a connecting factor for tax purposes from 6 April 2025, it may remain relevant for the application of double tax treaties. Therefore, it may still be necessary to determine an individual’s domicile status on or after 6 April 2025.

From 6 April 2025 onwards, liability to tax is based on system that depends on an individual’s UK residence pattern. See the Foreign income and gains regime ― overview guidance note for the rules that apply to income tax and capital gains tax. See the Residence-based IHT system from 6 April 2025 guidance note for the rules that apply