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Edition 1st
Published Second half of 2023
Length ca. 600 pages
Suitable for Accountants, Tax Advisers, Investors
Price 95
ISBN 9781912386659

Non-UK domiciled individuals


Availability: -

Publication of this book is targeted for the second half of 2023. Please call or email us to reserve your copy, without obligation.

Non-UK Domiciled Individuals UK Tax Compliance and Planning is a practical guide to the complexities of the UK tax system as it pertains to non-UK domiciled individuals. The book will include a thorough discussion of the law and of the relevant compliance issues. Tax mitigation strategies will be considered and traps in the legislation will be highlighted. 

Throughout the book there will be examples and case studies to illustrate the points made.

The focus of the book will be UK resident non-UK domiciled individuals. However, the territorial scope of UK legislation and its impact on non-UK resident and non-UK domiciled individuals will also be considered.  

Lynnette Bober MA (Cantab), MA in Law, BFP, FCA, CTA, TEP, MCIArb was called to the Bar in March 2021. She is a Tax Director at Gateley Legal.


 Domicile and why it matters for UK tax purposes
The concept of domicile and its place in the UK tax system
Domicile of origin
Domicile of dependency
Domicile of choice
Challenges to general law of domicile
Deemed UK domicile

 Income tax and CGT Fundamentals
Basis of taxation for UK resident non-UK domiciled individuals
Accessing the remittance basis
Long-term residents the remittance basis charge
Foreign income
Overseas workday relief
Foreign emoluments
Situs for CGT purposes
Foreign chargeable gains

 Income tax and CGT  Remitted to the UK
Statutory definition of "remitted to the UK"
Use directly or indirectly in respect of a relevant debt
Finance Act 2008 transitional reliefs
Relief for foreign income and gains used to pay the remittance basis charge
Business investment relief
Relief for certain UK services
Exempt property relief

 Income tax and CGT  The mixed fund rules
The mixed fund rules
Punitive mixed fund rules
Overseas workday relief - special rules for nominated account

 Trusts Special rules for non-UK domiciled individuals
The current position

 Deemed domiciled individuals
Basis of taxation for UK resident individuals with deemed UK domiciled
Trust protections

 Coming to and leaving the UK
Pre-arrival planning
Leaving the UK
The temporary non-UK resident provisions

 Inheritance tax
Territorial scope of IHT
Situs for IHT purposes
Application of the anti-avoidance legislation
Restriction on spouse exemption
Transferable nil-rate band and residential nil-rate band
IHT estate treaties

 Compliance / tax administration issues
Overview of the compliance framework
Relevant partial closure notices - case law
HMRC "one to many" campaigns
Interest and penalties
Making a disclosure to HMRC
The general anti-abuse rules

 Crystal ball gazing
What might the future hold?

 Table of primary legislation
 Table of statutory instruments
 Index of cases
 General index