Domicile is often confused with tax residence but they are not the same thing.

Domicile is determined from general law rather than tax law. It is possible to be tax resident in one country but domiciled in another.

Under English law, each person acquires a domicile at birth and this determines the relationship between the individual and the legal system with which he is most closely connected.

When reviewing a person's domicile, HM Revenue & Customs will try to establish where that person is considered to have his "permanent" home. There is no single legal definition for this and the interpretation of "permanent" may vary.

If you were born in the UK you will normally have acquired a UK domicile when you were born. It can be difficult to acquire a domicile anywhere else. Conversely, for non-UK nationals, a UK domicile is not automatically acquired when living in the UK.

Changes from April 2017

From 6 April 2017 new deemed domicile rules came into force.

If you aren’t domiciled in the UK under English common law you will be treated as domiciled in the UK for all tax purposes if certain conditions are.

If you meet the new deemed domicile rules you will no longer be able to claim the remittance basis of taxation and will be assessed on your worldwide income and gains on the arising basis.

In the UK, tax residence is based largely on physical presence, although other factors such as family, work, home and habitual time in the UK may need to be considered.

In calculating the number of days in the UK all days where you are in the UK at midnight will count as a day in the UK.

From April 2013 it became no longer enough to simply count your days in the UK in order to determine your residence status. From that date a statutory residence test was introduced - so that reliance on HMRC concessions is no longer needed. Also from that date, the concept of ‘ordinary residence’ was abolished.

For more details of the rules to determine tax residence status - check our page on the Statutory Residence Test.

Expatriate taxation is perhaps the most complex area of personal taxation, not least because it often involves the interaction of the tax systems of two countries.

Often, UK nationals will retain their UK property while seconded overseas so they retain a tax connection to the UK. We can help with annual tax return filing obligations to disclose continuing non-resident status and UK rental income.

There can be many pitfalls for the internationally mobile employee and tax  planning ahead of time is usually worthwhile.

We answer enquiries through our website for UK expatriates all over the world and for foreign nationals intending to work in the UK.

Need more information?

Have a look at our expat FAQs


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