ARTICLE · 27 FEBRUARY 2018

Non-Dom Changes – Formerly Domiciled Residents

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This briefing focuses on the recent tax changes affecting individuals born in the UK with a UK domicile of origin who return to the UK having acquired a domicile of choice overseas...

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This briefing focuses on the recent tax changes affecting individuals born in the UK with a UK domicile of origin who return to the UK having acquired a domicile of choice overseas (referred to as 'formerly domiciled residents'). These measures took effect from 6 April 2017.

Losing a UK Domicile of Origin

Domicile is generally construed as the place that an individual regards as their permanent home and with which they have the closest ties.

There are three types of domicile: domicile of origin, domicile of dependence and domicile of choice.

An individual has a "domicile of origin" which is fixed at birth and usually follows the domicile status of the individual's father if he was alive at the time of the birth and married to the individual's mother.

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