Official Statistics

Statistical commentary on non-domiciled taxpayers in the UK

Updated 6 July 2023

1. Summary of key statistics

Figure 1: Aggregated numbers and liabilities for both non-domiciled and deemed domicile taxpayers

Key findings from this year’s publication are:

  • In the tax year ending 2022, we estimate a combined total of at least 78,700 non-domiciled and deemed domiciled taxpayers are indicated in Self Assessment (SA) tax returns with combined total Income Tax, Capital Gains Tax (CGT) and National Insurance contributions of at least £12.4 billion, up from 78,100 taxpayers and £11.3 billion, respectively, in the previous tax year

  • The combined tax and NICs liabilities of £12.4 billion for tax year ending 2022 for all non-domiciled and deemed domiciled taxpayers is the largest annual tax liability from this combined group since our figures began in 2008 (illustrated by Figure 1)

  • There is some evidence of a recovery in tax year ending 2022 in newly arrived non-domiciled taxpayers following the drop in the previous tax year in which taxpayers were subject to COVID-19 related travel restrictions; the increase in numbers may also be supported by some evidence of improved retention of existing non-domiciled taxpayers compared with the previous tax year (illustrated by Figure 3)

  • Deemed domiciled taxpayers alone have UK tax liabilities of at least £3,946 million in tax year ending 2022, so are liable for at least 30 percent of the combined total for non-domiciled and deemed domiciled taxpayers, however, we are conscious that not all deemed domiciled taxpayers need indicate their status on their tax returns, so their liabilities are likely to be larger still

  • For the remittance basis population we publish these figures a year in arrears with the latest figures from tax year ending 2021, when taxpayers were subject to COVID-19 related travel restrictions, showing that the number of remittance basis taxpayers fell by over 7,000 where the majority of this decrease (circa 4,000) came from a reduction in taxpayers who have less than £2,000 of unremitted overseas income

  • Since the 2017 deemed domiciled reforms the number of taxpayers paying the Remittance Basis Charge (RBC) has been increasing

Figure 2: Non-domiciled taxpayer numbers, Income Tax, Capital Gains Tax and National Insurance contributions

2. About this release

This publication is the annual update of statistics on individuals who are non-domiciled or deemed domiciled for tax purposes. To qualify as a non-domiciled taxpayer an individual must have their permanent home, their ‘domicile’, outside the UK. They must also claim non-domiciled status in the UK for tax purposes on their UK SA tax returns. Deemed domiciles are formerly non-domiciled taxpayers indicating on their UK SA tax returns that they are now treated as domiciled in the UK for the purposes of Income and Capital Gains Tax. This is following on from the 2017 change to end permanent non-domiciled taxpayer status in the UK for non-domiciles who were either born in the UK and have been UK resident since tax year ending 2018, or have been UK resident for at least 15 of the 20 tax years immediately before the relevant tax year. Figures for tax years ending 2020, 2021 and 2022 are provisional (subject to future updates), all other figures are final (will not be further updated).

From 6 April 2020, individuals, trustees and personal representatives of deceased persons who sell or otherwise dispose of UK residential property where Capital Gains Tax (CGT) is due on all or part of the gain have had to report the disposal to HMRC within 30 days of completing the disposal, and at the same time make a payment on account of the CGT due. These statistics, for the first time, also include tax liabilities reported using the new Capital Gains Tax on UK property service for tax year ending 2021 and tax year ending 2022. We have found that the inclusion of this data increases annual tax liabilities by less than £5 million per tax year.

Following on from a recent statistics consultation we have made some amendments to this publication - Tables 3, 8, 12 and 15 have been removed from the accompanying spreadsheet, Tables 13, 14 and elements of Table 15 have been combined into a single table which is now Table 10. We have updated CGT liabilities for tax years ending 2021 and 2022, and removed the former Figures 5, 7 and 9 from the main commentary and shortened the time series in most tables and figures to include the previous 8 tax years where applicable.

The historic data and tables remain available in the Government Web Archive.

3. Non-domiciled taxpayers and taxes

Figure 3: Number of non-domiciled taxpayers who have arrived into the UK in the previous five tax years

Figure 3 shows that for tax year ending 2022 there has been an increase in the number of newly arrived non-domiciled taxpayers compared to newly arrived non-domiciled taxpayers in tax year ending 2021. However, this number still remains lower than newly arrived non-domiciled taxpayers in tax year ending 2020. Last year we outlined that the decrease in the number of newly arrived non-domiciled taxpayers in tax year ending 2021 might be partly explained by the COVID-19 related travel restrictions in place affecting the availability of aviation, sea or rail travel into the UK for much of that tax year.

Figure 3 also shows that the number of non-domiciled taxpayers who have stayed for a second year in tax year ending 2022 is lower than in previous years. This may again be partly due to the knock-on effect of fewer non-domiciled taxpayers coming to the UK in tax year ending 2021, when COVID-19 related travel restrictions were in place. However, it does show that of those non-domiciled taxpayers who did arrive in the UK during tax year ending 2021, they have largely stayed in the UK. This suggests a higher-than-normal rate of retention of non-domiciled taxpayers between a first and second year in the UK.

We estimate that there were 68,800 individuals claiming non-domiciled taxpayer status in the UK on their SA tax returns in the tax year ending 2022, up from 68,000 in the tax year ending 2021. As such, the increase in the number of non-domiciled taxpayers in tax year ending 2022 on the previous year may be explained by a recovery in new arrivals numbers and better retention rates reducing the outflow of non-domiciled taxpayers. However, the number of non-domiciled taxpayers has not recovered to the numbers seen pre-pandemic when in tax year ending 2020 there were 77,300 non-domiciled taxpayers.

We expect, given Figure 3, that the overall number of non-domiciled taxpayers will remain affected by the lower than normal number of new arrivals in tax year ending 2021 for around a further two tax years.

We estimate that in the tax year ending 2022, the amount of UK Income Tax, Capital Gains Tax and National Insurance contributions liable by all non-domiciled taxpayers was £8,490 million. Despite the relatively small increase in the number of non-domiciled taxpayers since tax year ending 2021, the total amount of tax and NICs liabilities has increased by over £500 million. Overall, of all non-domiciled taxpayers in the tax year ending 2022, the majority indicated UK residence as in previous years.

The number of non-domiciled taxpayers who are non-UK resident can be calculated by subtracting the number of individuals in Table 2 from the number of individuals in Table 1 in the accompanying spreadsheet. Overall, the number of non-domiciled non-UK resident taxpayers has been gradually declining from 14,600 in tax year ending 2018 to 13,600 in tax year ending 2022.

The following section suggests the fall in non-domiciled taxpayer numbers in the tax year ending 2018 is largely explained by the deemed domicile reforms introduced in April 2017 (labelled in Figure 4 as tax year ending 2018). This meant that an individual who was formerly non-domiciled might be deemed domiciled for tax purposes if they were born in the UK and have a UK domicile of origin (Condition A), or if they were resident in the UK for at least 15 of the 20 tax years immediately before the relevant tax year (Condition B).

4. Deemed domicile reforms

Figure 4: Deemed domiciled taxpayer numbers, Income Tax, Capital Gains Tax and National Insurance contributions

Figure 4 shows 9,900 individuals indicated deemed domiciled taxpayer status in the UK on their SA tax returns in the tax year ending 2022. This is a slight reduction on the number of deemed domiciled taxpayers in the tax year ending 2021, following three years of consistent increases. We have applied a late filing correction to the data for tax year ending 2022. This is consistent with our normal approach to publishing non-domicile figures for the current tax year as we are aware that late filing of tax returns does take place.

We believe that there are likely to be a larger number of deemed domiciled taxpayers than this as there are different incentives for the different deemed domicile groups. Those under condition A who have a UK domicile of origin do not have access to the range of transitional protections that were available for condition B deemed domiciles who do not have a UK domicile of origin. This means that only the condition B deemed domicile group has a strong incentive to tell us they consider themselves to be deemed and to continue to complete the SA109 form. This is to remind us that they consider themselves to be maintaining a common law non-domicile status despite having been deemed to be UK domiciled in the UK tax system.

We estimate that in the tax year ending 2022, the amount of UK Income Tax, Capital Gains Tax and National Insurance contributions on worldwide income and gains liable by those taxpayers indicating deemed domicile status was £3,946 million. This is an increase from last year’s estimate of £3,432 million.

This analysis shows that decreases in the number of non-domiciled taxpayers and tax liabilities in tax year ending 2018 can be substantially explained by taxpayers becoming deemed domiciled in the UK. Despite the fall in exchequer revenue exclusively from the non-domiciled population shown in Figure 2 since tax year ending 2018, Figure 1 now shows any fall in revenue has been more than offset by the deemed domiciled taxpayers who have been liable for more tax year-on-year since tax year ending 2018.

5. Guidance for interpretation of figures in this release

We have provided provisional figures for the tax year ending 2022 for Tables 1 to 3 only (in the accompanying spreadsheet). Figures for the three most recent tax years published may be revised in the future and the difference between them and previous years may be reduced or disappear. Further breakdown of the figures for the current year are not included as the source data is not complete enough to be a reliable indicator of longer-term trends (particularly where two successive years’ data points are close together as updates to the data in these instances may mean increases may change to decreases) and will be included in next year’s publication when the data is more settled. For the rest of this publication, we will discuss tax years up to tax year ending 2021.

6. Non-domiciled UK resident taxpayers, remittance basis and arising basis

The vast majority of non-domiciled taxpayers are UK resident. For the tax year ending 2021, in Figure 5, the number of UK-resident non-domiciled taxpayers fell from 63,400 to 54,300, compared with a fall from 77,300 to 68,000 for all non-domiciled taxpayers (as seen in Figure 2). This may be due to the COVID-19 pandemic and the travel restrictions that were in place, given that we are publishing a year in arrears, rather than for the most recent tax year ending 2022. The UK resident non-domiciled group is taxed on two bases: a remittance basis or an arising basis.

Individuals who are UK resident are normally taxed on the arising basis of taxation, so that all of that individual’s worldwide income and gains are taxable in the UK as they arise. Some non-domiciled taxpayers who are UK resident may choose to be taxed on the remittance basis, meaning that any foreign income and gains will only be taxed if they are brought, or remitted, into the UK, even if that remittance occurs in a later tax year. For non-domiciled taxpayers who opt to be taxed on the remittance basis, any foreign income and gains that are not remitted to the UK are not subject to UK tax.

Those taxed on a remittance basis make up a larger proportion of non-domiciled UK residents. Figure 5 shows that the number of non-domiciled taxpayers on the arising basis has been broadly stable since 2018. The number of non-domiciled taxpayers on the remittance basis was broadly stable from tax years ending 2018 to 2020, but this has dropped in tax year ending 2021. As we have indicated this may largely be due to the COVID-19 pandemic and the related travel restrictions.

Figure 5: Number of non-domiciled UK residents claiming the remittance basis or the arising basis of taxation

Tables 4 and 5 in the accompanying spreadsheet contain the information for the total UK Income Tax, CGT and NICs contributions for the UK resident non-domiciled taxpayers claiming the remittance basis and also the arising basis.

Please note Tables 4 and 5 will not include some individuals who pay tax on the arising basis without indicating non-domiciled or deemed domiciled status on the SA return, in particular taxpayers who were considered non-domiciled, but are now deemed to be domiciled and have moved onto the arising basis. The number of taxpayers on the arising basis and their taxes and NICs liabilities dropped substantially between tax years ending 2016 and 2017, and continued to fall in recent years, although their tax contributions may now have stabilised.

7. Remittance basis and the remittance basis charge

7.1 Population changes

The number of non-domiciled taxpayers paying on the remittance basis was 37,000 in the tax year ending 2021. We expect to revise this in future years due to a small number of late filers.

Figure 6 shows a fall in the number of remittance basis claimants in tax year ending 2021 of over 7,000. The majority of this decrease (circa 4,000) can be explained by the substantial drop in the number of remittance basis taxpayers who have got unremitted income of below £2,000 which can be seen in Table 7 of the accompanying tables. As we have indicated this may be due to the COVID-19 pandemic and the related travel restrictions.

Table 6 shows that only a minority of the taxpayers who are using the remittance basis are liable to pay the RBC. This is because the RBC is only levied when a remittance basis user has been UK resident for at least 7 of the previous 9 tax years immediately before the relevant tax year. It is also not payable where a taxpayer using the remittance basis has less than £2,000 of unremitted non-UK income or gains. We have provided a breakdown for this group in Table 7.

7.2 Remittance basis claimants and taxes

Figure 6: Number of non-domiciled UK resident taxpayers taxed on the remittance basis and their Income Tax, Capital Gains Tax and National Insurance contributions

Non-domiciled taxpayers on the remittance basis in the tax year ending 2021 are liable to pay £6,194 million in Income Tax, Capital Gains Tax and National Insurance contributions (Table 4). This is a decrease from 2020 of circa £180 million and remains below the high point in the tax year ending 2017. Just over £40 million of this decrease can be explained by the sub-group population of non-domiciled taxpayers who have less than £2,000 of unremitted overseas income (Table 7). We explained earlier in this release that tax and NICs liabilities from deemed domicile taxpayers exceed the decrease in remittance basis user liabilities that followed the tax year ending 2017.

8. Remittance basis charge revenue

Figure 7: Non-domiciled UK resident taxpayers liable to pay the remittance basis charge and UK Income Tax, Capital Gains Tax, National Insurance contributions and remittance basis charge revenue

Figure 7 shows the number of taxpayers who were liable to pay the RBC rose from 1,800 in the tax year ending 2018 to 2,100 in the tax year ending 2021. The total amount to be paid by taxpayers in Income Tax, CGT, NICs and the RBC also rose from £838 million from those who were liable to pay the RBC in the tax year ending 2018 to £1,231 million from those who were liable to pay the RBC in the tax year ending 2021.

This shows that the number of remittance basis users who are staying resident in the UK long enough to pay the RBC has been steadily increasing since the 2017 deemed domicile reforms, with their tax and NICs liabilities increasing by over £250 million in tax year ending 2021 on the previous tax year. This is a much larger proportional increase than their respective increase in population numbers.

The accompanying background quality report provides more details on the remittance basis charge and deemed domiciled changes.

9. Non-domiciled taxpayers by region

9.1 Regional observations

London continued to have the largest non-domiciled taxpayer population in the tax year ending 2021, with 57% of non-domiciled taxpayers in the UK located in that region and 74% of non-domiciled UK Income Tax, CGT and NICs coming from that region. This information is shown in the accompanying spreadsheet in Table 10. London also had the largest population of UK resident non-domiciled taxpayers. The last two years of data show that the tax liabilities are increasingly concentrated from people in London.

10. Business Investment Relief in the UK

Figure 8: Value of business investment relief and number of claimants

Figure 8 shows that in the tax year ending 2021, the cumulative value of investments in UK businesses on which Business Investment Relief (BIR) has been claimed since BIR began in 2012, is £7,039 million. In the tax year ending 2021 alone, £739 million was invested in the UK from 500 taxpayers which is down by circa £110 million from the previous year.