Domicile

is a complex tax topic that is not relevant to many people’s tax affairs if they are non-resident but is likely to have a bearing on Inheritance Tax when someone dies.

Domicile is an abstract concept that ignores nationality, where someone is a citizen and where they live.

Confusingly, an expat can have three domiciles:

Domicile of origin

This is where your father was domiciled when you were born, but is not necessarily the same place

Domicile of dependence

For someone under 16 years old, their domicile follows suit when the person they are dependent on changes their domicile

Domicile of choice

For someone aged 16 or over, who can show:

• They are living permanently in a new country they consider is home
• They intend to stay in the new country for good
• All personal ties have been broken with the country which was their domicile of origin

Some countries, like the UK, also label a ‘deemed domicile’. This means some expats who are non-residents are treated as UK residents for tax.

This affects expats who are:

• Domiciled outside the UK but were born or had a domicile of origin in the UK
• Tax resident for 15 out of the past 20 years in the UK