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Residence and domicile

Expert commentary and practical guidance from ICAEW related to residence and domicile in the UK personal tax regime, including offshore investments,

In this section

Practical guidance

ICAEW's Tax Faculty produces TAXguides to provide practical support on technical areas of tax

TAXguide 08/21: COVID-19: Displaced expatriate employees

This TAXguide contains correspondence between ICAEW, the Financial Secretary to the Treasury and HMRC on the statutory residence test and social security in relation to expatriate employees that have been displaced due to the impacts of the coronavirus pandemic. This TAXguide replaces TAXguide 06/21 which predated HMRC’s reply on social security contributions.

TAXguide 02/21: Deemed domicile changes - trust protections

Guidance from ICAEW, STEP, and the CIOT to highlight practical issues and uncertainties in the statutory provisions for trust protections introduced by Finance (No 2) Act 2017. This guide is formed of notes prepared by the professional bodies covers issues, such as: de minimis, guarantees, property management and offshore income gains.

TAXguide 03/21: Deemed domicile changes - trust protections and OIGs

Guidance from ICAEW, STEP, and the CIOT to highlight a key issue with respect to the trust protections as introduced by Finance (No 2) Act 2017. This guide focuses on the situation where the settlor is deemed UK domiciled only under the 15-year rule and offshore income gains arise directly to the non-UK resident trust.

Features and articles

Inheritance tax: pitfalls and planning points

Inheritance tax has been in the public eye again in recent months, sparking media debate on the merits and demerits of one of the UK’s least favourite taxes. Mei Lim Cooper looks at some of the pitfalls and planning points for inheritance tax as it stands.

Tax news in brief 6 July

Highlights from the broader tax news for the week ending 6 July 2022, including: L-Day; tax credit renewals; ID for government gateway; HMRC survey on forms; residence indicator tool; CHIEF closed to new importers; and an updated partial exemption toolkit.

Webinars and recordings

Bloomsbury Accounting and Tax Service

Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising more than 60 titles from some of the country's leading tax and accounting subject matter experts. Find out who is eligible and how you can access the Accounting and Tax Service.

Land and property

Expert commentary on the current capital gains tax legislation related to the taxation of land and property in the UK.


A full chapter on residence status rules and double taxation relief in relation to UK income tax.

The international dimension

Three chapters providing tax planning advice related to domicile, residence, international tax and double tax relief.

Property investment

Expert commentary on the current UK corporation tax legislation related to property investment.

Tax planning for the non-resident and non-domiciled

A chapter on tax planning for the non-resident and non-domiciled, highlighting tax planning opportunities and potential pitfalls.

Non-resident CGT and UK land

A chapter on taxation relevant to non-resident investors in UK land, highlighting tax planning opportunities and potential pitfalls.

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Residence and domicile

A chapter covering the concepts of residence and domicile, and their respective implications for an individual’s liability to Income Tax, Capital Gains Tax, and Inheritance Tax in the UK. The author gives tax saving tips, and illustrates points with real-world examples.

Overseas aspects of taxation

This chapter summarises the tests of residence and domicile for tax purposes, as well as double taxation arrangements and personal allowances.

Capital Gains Tax

An overview of Capital Gains Tax, covering: exemptions; residence and domicile; annual exemption and losses; capital gains tax rate; disposal consideration; date of disposal; allowable costs; married couples; disposal to connected parties; part disposals and shares.

Overseas aspects of taxation

This chapter deals with overseas income and gains of UK-resident individuals and companies, with a brief note on non-residents whose income arises in the UK. The chapter covers residence and domicile, general rules pertaining to the major taxes, and double taxation relief.

Terms of use: You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the terms of use set by our suppliers and any restrictions imposed by individual publishers. Please see individual supplier pages for full terms of use.

Markel Tax FAQs

Questions and answers on UK tax issues and trends from the ICAEW Tax and VAT Helpline, a subscription service provided by Markel Tax.

SDLT and sole ownership

FAQ on whether a married couple, who live jointly in a house owned solely in the wife's name, can avoid paying the higher rates of stamp duty land tax, if they buy their new property solely in the husbands name, whilst keeping the original property to rent out.

SDLT and non-UK company shareholders

FAQ about whether the additional 2% rate of stamp duty land tax for non-residents will apply to a limited, UK-registered property letting company, whose shareholders moved out of the UK in the previous tax year and are now non-residents for tax purposes.

Markel Tax FAQs are correct at the time of going to press. To check current validity, please call the ICAEW Tax and VAT Helpline.


ICAEW REP 001-22 Corporate redomiciliation

ICAEW’s Business Law and Tax Faculties respond to BEIS and HMRC proposals to introduce a facility for companies incorporated overseas to transfer their place of registration to the UK.

ICAEW REP 95/21 Autumn Budget 2021 representations - Building a modern tax system

A response dated 5 October 2021 to a consultation published by HMT on 30 September 2021, including ICAEW’s Tax Faculty customary pre-Budget letter to the Financial Secretary to the Treasury. It calls for the acceleration of work to build a modern tax system, while urging a “manageable pace” of transition, it cautions against implementing tax changes without consultation, such as the new Health and Social Care Levy.

Further support

Useful links

Some resources that we link to may pre-date the latest amendments to the relevant tax regulations. While these links contain useful information, please treat them with appropriate caution.

Tax obligations for non-residents working in Hong Kong

<p>Information from the HKSAR government on chargeable and non-chargeable income from temporary residents. Also covers tax clearance when leaving Hong Kong SAR. </p>

Tax on your UK income if you live abroad

Guidance providing an overview of taxable income, including rental income and selling or inheriting assets. It discusses personal allowances, tax reliefs available and how to claim tax reliefs, and the situation for UK residents.

Tax if you leave the UK to live abroad

Guidance for UK taxpayers with links to forms and tax returns required by HMRC, plus information on tax refunds, UK income, and National Insurance.

Tax on foreign income

Guidance aimed at taxpayers covering UK residence and tax, non-domiciled residents, paying tax on foreign income, exemptions, claiming tax relief, and tax for foreign students in the UK.

Residence, Domicile and Remittance Basis Manual

HMRC internal manual providing guidance for those leaving and coming to the UK on residence and domicile status, UK tax liability and personal allowances - including guidance on particular occupations.

Common Reporting Standard

Comprehensive topic guide on the CRS regime, background and aims, its relationship to FATCA, the status of the Alternative Reporting Regime for UK Resident Non-Domiciles, and enforcement.

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