The rules came into effect last April and mean that those not domiciled under common law are treated as domiciled in the UK if one of two conditions are met.
Under ‘condition A’, a person is a deemed to be UK domiciled if they were born in the UK, have the UK as their domicile of origin or are resident in 2017/18 or subsequently.
Under ‘condition B’, a person is deemed domicile if they have been resident for at least 15 of the past 20 years.
Those who are deemed domicile will no longer be able to claim the remittance basis of taxation and will be assessed on their worldwide income and gains whether it is brought into the UK or not.
The guidance includes examples of when individuals are deemed domicile.
The measures were introduced retrospectively in the 2017 Finance Bill and are designed to reduce the numbers of wealth long-term residents claiming the more favourable remittance basis of taxation.
Critics have warned the measures will push wealth out of the UK and into offshore centres.
