The tapestry of life: Domicile in the modern private client arena

In 2017, as many private client practitioners will remember, significant changes were made to the taxation of foreign domiciliaries. The changes fell broadly into three categories. First, there was new law on when individuals would be deemed to have a domicile in the UK based on either long-term residence in the UK, or a combination of their domicile of origin and a current UK tax residence. Secondly, there were protections introduced for settlements established by non-doms who became deemed domiciled here under the new long-term residence rule. Thirdly, there was an overhaul of the Inheritance Tax treatment of offshore holding structures for UK residential property.