Coller v HMRC: Actions Speak Louder Than Words

While the concept of acquiring a domicile (deemed) after 15 tax years of UK residence is familiar to many, it is vital that common law domicile is not overlooked.

The recent judgement (all 57 pages of it) of the First-Tier Tax Tribunal delivered by Tribunal Judge Nigel Popplewell in Jeremy Coller v HMRC ¹ provides an excellent reminder. Briefly, the facts were that Mr Coller claimed, for the purposes of claiming the remittance basis of taxation, that he was not domiciled in the UK ² by virtue of his parentage. All domicile cases are, by their very nature, fact specific but the Tribunal Judge went above and beyond to provide a thorough exposition of the law of domicile in his application to Mr Coller's life history and addressed a number of issues which often arise in such cases.