DOMICILE

Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...

Determining domicile: In A Weis v HMRC [2025] UKFTT 348 (TC) (21 March), the taxpayer, a Rabbi, had been born in the UK in 1949 in Manchester to a father who had been born in Eastern Europe but had come to the UK in 1938. The father had acquired...

Emma Chamberlain

Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.

Dominic Lawrance

Sophie Dworetzsky

Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) share their views on the current tax regime for UK resident non-domiciled individuals and what might happen under a Labour government.

Claire Weeks

Clare Maurice

Claire Weeks and Clare Maurice (Maurice Turnor Gardner) explain why returning to the UK after a period of non-tax residence is not for the faint hearted.

Hugh Gunson

Louise Paterson

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.

Kathryn Hart

Edward Reed

Domicile disputes, exceptional circumstances, judicial review... Edward Reed and Kathryn Hart (Macfarlanes) review recent developments in the private client world.

Establishing domicile and whether tax loss due to carelessness

HICBC and discovery assessment powers: There is no sign of the flow of high income child benefit charge (HICBC) cases drying up. HMRC presumably hoped that the retrospective legislation to reverse the decision in Wilkes [2020] UKUT 150 (TCC), where...

Catrin Harrison

Dominic Lawrance

Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine the Court of Appeal’s decision on partial closure notices in respect of domicile cases.

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