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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Domicile: Deemed domicile: Counting the number of years

For the purposes of working out the number of years of UK residence to calculate whether or not an individual is deemed domiciled, all UK tax years of residence must be counted including:

  • all UK resident tax years under the age of 18
  • any tax year which is split into a UK part and an overseas part will be counted as a year of UK residence. (If a person either departs from or arrives in the UK  during a tax year). For more information on split years and the Statutory Residence Test (SRT) please see the RDR3 chapter 5.

Example 1

Sergei, who does not have a UK domicile of origin, came to the UK to attend secondary school at the age of 11 on 20 July 2000. He remained in the UK to attend university and subsequently commenced employment here. From September 2000 until July 2008 he was at school, and from September 2008 he was at university. From October 2011 Sergei worked in London.

Segei has been in the UK for 17 years. For 7 of those years, he was under the age of 18. However, all these years will count when working out whether Sergei has become deemed domiciled for UK tax purposes, to see whether he has met Condition B. In this case he will be deemed domiciled and will be taxed on his worldwide income from 2017-2018, the first year these new rules came into force.

Example 2

Constance does not have a UK domicile of origin at birth. She came to the UK on 6 May 2013 and was resident from this date, (split year treatment applies). She remained in the UK for the next 6 years, before leaving on the 30 November 2019 for full time employment overseas in Switzerland. Split year treatment applies for the year 2019-2020.

Constance remains in Switzerland for 3 years and returns to the UK on the 21 September 2022. Split year treatment applies for 2022-2023.

She remains in the UK for 18 months, leaving on 20 March 2025, taking up overseas employment in Singapore. Split year treatment applies for 2024-2025. Constance remains there until 1 October 2028 when she comes back to live and work full time in the UK, and again split year treatment applies for 2028-2029.

As Constance remains in the UK she will become deemed domicile from 6 April 2033.

2013-2014 resident (split year treatment)

2014-2015 resident

2015-2016 resident

2016-2017 resident

2017-2018 resident

2018-2019 resident

2019-2020 resident (split year treatment)

2020-2021 not resident

2021-2022 not resident

2022-2023 resident (split year treatment)

2023-2024 resident

2024-2025 resident (split year treatment)

2025-2026 not resident

2026-2027 not resident

2027- 2028 not resident

2028-2029 resident (split year treatment)

2029-2030 resident

2030-2031 resident

2031-2032 resident

2032-3033 resident

2033-2034 resident

Constance will be deemed domiciled in the UK from 2033-2034.