Deemed domicile with effect from 6 April 2017 for all tax purposes – consultation document

Two categories of persons will be affected by the proposed changes:

• Non-UK domiciled individuals who have resided in the UK for at least 15 out of the last 20 tax years before the year under consideration
• Individuals, who were born in the UK, acquired a UK domicile of origin at birth and later left the UK and acquired a non-UK domicile of choice, but have then returned to the UK and become resident, but not UK domiciled.

The latter in particular means that the remittance basis would no longer be available. Depending on personal circumstances and assets it might be necessary to leave the UK before 5 April 2017.