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HMRC internal manual

Inheritance Tax Manual

Other domicile issues: Double domicile

Under common law it is not possible to be domiciled in two countries at the same time and certainly not for the same purpose at the same time. But, for the purposes of charging Inheritance Tax (IHT) having two different domiciles for the same purpose at the same time is key to the concept of deemed domicile.

Double domicile, is a term that describes the situation where there is a conflict between the application of UK domicile rules and the equivalent international law rules of a foreign country.

So, someone who has a common law domicile in Texas but is a long term resident of England may have an English domicile for IHT because of the deemed domicile rules for IHT (IHTM13024).

It is not necessarily a problem that needs to be resolved because we apply UK law only.

However, in the case of the double taxation conventions we need to establish one domicile (fiscal domicile) and each convention contains rules for resolving any conflict. You must discuss any case where this applies with Technical.