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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

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HM Revenue & Customs
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Domicile: Illustrative Scenarios: Mr H

H was born in France to married parents whose ancestors had lived in France for several generations and had no substantial links elsewhere. H’s domicile of origin is France.

During H’s childhood his parents emigrated to the Swiss canton of Vaud with the intention of remaining there permanently. H acquired a domicile of dependence in Vaud at that time.

H attended business school in the USA, after which he obtained a job in London. H married an English woman, bought a flat in Hampstead and a house in Oxfordshire, had children, and settled in England without any intention of living elsewhere. H acquired a domicile of choice in England and Wales at some point during his adult life, although it might be difficult to say precisely when this happened.

H’s operative domicile was originally France. It was then Vaud. Following his departure from Vaud, H’s French domicile might have become operative again, depending on the circumstances. At some point England and Wales became H’s operative domicile.

Refer to RDRM22100, RDRM22200, RDRM22300,