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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

From
HM Revenue & Customs
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Residence: Coming to the United Kingdom: What this chapter is about

This chapter tells you how to deal with individuals who are coming to the UK.

If an individual comes to live in the UK permanently, or to work for an extended period, or with no particular end date, they will become resident in the UK. But not everyone who comes to the UK will become resident here, e.g. those who are in the UK on holiday or for a short period of work.

In most cases it will be clear whether an individual becomes resident or not, but sometimes it needs careful consideration of a number of factors. The following guidance will help you to consider various factors in order to decide if, and when an individual becomes resident in the UK, and what this means for the tax they pay.

Coming to the UK permanently, indefinitely, or for three years or more

If an individual’s home has been abroad and they have come to the UK to live here permanently or indefinitely, they will be resident and ordinarily resident from the date they arrive. An individual will also be resident and ordinarily resident from the date they arrive if they have come to the UK to remain here for three years or more. This is because they are not simply visiting but have a settled purpose.

Coming to the UK for shorter periods of time

If an individual is simply visiting the UK then they might not be resident. However an individual is not simply visiting the UK if they have a purpose for being here which is not temporary. The nature and extent of their connections to the UK may indicate that their purpose in the UK is not temporary.

If an individual remains in the UK for a period that spans two tax years and they are resident in the second year then you will need to consider whether they were also resident in the first year. This will depend on all the facts.

It is also possible that after an individual first comes to the UK their circumstances change and they are now going to live here permanently or indefinitely, or are going to remain here for three years or more from the date of their arrival.