Chris Thorpe considers recent announcements concerning ‘non-dom’ status.
For over a hundred years, the remittance basis has been in place for those not domiciled in the UK (non-doms).
However, in April 2024, it was announced that the foundation for the remittance basis will change from domicile to physical residence in the UK from April 2025. Also, changes were announced with respect to exposure to inheritance tax (IHT) from the ‘deemed domicile’ rules.
Non-domicile
Under UK common law, everyone has a domicile assigned at birth (i.e., a ‘domicile of origin’), which in England and Wales reflects one’s father’s domicile (assuming the parents are married). Children under 16 take their father’s domicile, with women married before 1 January 1974 taking that of their husband (domicile of dependence).
