Long-Term Residents – Background Print

Non-domiciles who have been resident in the UK for more than 15 out of the past 20 tax years are no longer able to claim the remittance basis and are treated as deemed domiciled in the UK for all tax purposes.

Residence for each year is based on the rules applying at the time for the year in question, so the Statutory Residence Test only applies from 6 April 2013.

Minor children are treated in the same way as adults, so a non-domiciled minor child may become deemed domiciled in the UK before attaining the age of 18.

To break the deemed domicile for income tax, or CGT purposes the non-domiciled individual must become not resident in the UK for at least 6 tax years. In this connection any Split-year is treated as a year of residence in the UK.

A number of measures were introduced to dissuade long-term non-domiciles from leaving the UK before 6 April 2017 when the new regime for long-term residents came into effect. In addition to trust protection discussed above, the following transitional reliefs were introduced:

Rebasing

Mixed Fund Cleansing

Trusts

Offshore Companies

Capital Gains Tax

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