With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.
Domicile continues to attract significant HMRC scrutiny
The concept of common-law domicile is of central importance to tax and succession for individuals with UK connections. It affects among other things their entitlement to claim the remittance basis their exposure to IHT the tax treatment of trusts and even succession to their estates.
Briefly an individual’s common-law domicile is determined in one of three ways:
domicile of origin: acquired at birth usually on the basis of one’s father’s domicile;
domicile of dependency: acquired by a dependent person during their minority from the person on whom they are dependent (again usually from one’s father); and
domicile of choice: acquired by a taxpayer making their...
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With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.
Domicile continues to attract significant HMRC scrutiny
The concept of common-law domicile is of central importance to tax and succession for individuals with UK connections. It affects among other things their entitlement to claim the remittance basis their exposure to IHT the tax treatment of trusts and even succession to their estates.
Briefly an individual’s common-law domicile is determined in one of three ways:
domicile of origin: acquired at birth usually on the basis of one’s father’s domicile;
domicile of dependency: acquired by a dependent person during their minority from the person on whom they are dependent (again usually from one’s father); and
domicile of choice: acquired by a taxpayer making their...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
