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Non-doms not deterred by 2017 deemed domicile reforms

18 November 2024
Issue: 4962 / Categories: News

Most taxpayers affected by the 2017 deemed domicile reforms remained in the UK and paid more tax on average since becoming deemed domiciled according to a recent report from HMRC. The increase in tax paid has been driven by those who have historically paid relatively more tax paying an even greater amount of tax.

The 2017 changes meant that some non-domiciled taxpayers were to be deemed as domiciled in the UK through either:

  • being born in the UK with a domicile of origin of the UK and resident in the UK in tax year 2017 to 2018 or later (condition A); or
  • being UK-resident for at least 15 of the 20 tax years immediately before the relevant tax year (condition B).

This brought more people into scope of UK taxation on their income and capital gains.

The research found that deemed domiciled taxpayers...

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