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Change of heart
Key points
- The Gulliver case confirmed that a domicile ruling for one year will not bind HMRC into the future.
- Clients should complete HMRC forms IHT401 (Domicile) for the adviser to review.
- The HMRC manuals and the Gulliver case show that domicile status depends on many factors.
- Unintentional statements by a client regarding their long-term plans may be indicative of domicile.
- The domicile report should cover basic principles factors and tax implications.
- HMRC now has an extended time limit to investigate offshore matters.
- The indemnity section of the domicile report may be critical.
Those who have moved or retired abroad ostensibly forever or even those who are intending to change their domicile of origin of UK to one of choice in another country often seek a detailed report covering their current or future position. See ‘A word of warning’ at the end of this article. In the...
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