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Hong Kong bound
KEY POINTS
- HMRC was entitled to open an enquiry about a taxpayer’s domicile despite accepting he had a domicile of choice in Hong Kong in another year.
- Written assurances from HMRC should not be regarded as a golden ticket on domicile status.
- Consider keeping accurate records to assist with any HMRC enquiry.
Domicile is a legal concept based on an individual’s long-term intentions as to the country they wish to live in. It is not the same as residence which for tax purposes is based mainly on the time an individual is present in the UK in a tax year.
In the past HMRC has given rulings on domicile but how much reliance can be placed on a previous decision when considering later tax years? This question came before the First-tier Tribunal in Gulliver (TC5712).
The taxpayer was...
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