Domicile limbo

As inheritance tax is due if the settlor is considered UK domiciled and isn't if he is not this transaction forces HMRC to consider domicile.
However of late it appears that HMRC are refusing to give a domicile ruling in cases even where tax is at stake.
A recent case involved the creation of a discretionary trust by a non-resident British national where the potential tax liability was £11 000 not an insignificant amount. But the response from Capital Taxes Office was that 'the amount of tax at issue in this case does not justify the substantial costs of considering whether the domicile of the settlor had changed at the date of transfer. The IHT 100 is therefore being filed without further investigation. Any future transfers of value by the settlor will be considered at that time and in accordance with our normal procedures'.
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