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HMRC internal manual

Capital Gains Manual

Becoming domiciled

An individual who is resident or ordinarily resident* but who has not been domiciled in the UK may change his or her domicile status and become domiciled in the UK from some date. If that individual

* realised gains on foreign assets in the period when he or she was resident or ordinarily resident* but not domiciled


* remits those gains after becoming domiciled

he or she should be assessed on the gains remitted in accordance with TCGA92/S12. The fact that he or she has become domiciled does not prevent assessment of the gains on the remittance basis.

  • The ordinarily resident test only applies for the years up to and including 2012/13.