Residence & Domicile

Changes to the residence rules now included in Income Tax 2007 are extremely complex to say nothing to whether or not they are workable in practice.

The Act now sets out a new basis of charge for people who are resident in UK but are non-domiciliaries or not domiciled in England or other countries within the UK or are not ordinarily resident in UK.

Clients will need to understand from the new rules key aspects such as:

• Who can or should use the remittance basis
• The mechanism for the new £30,000 annual charge for longer term resident non-domiciliaries
• Knowing whether one has remitted (or is deemed to have remitted) foreign income and gains to UK, taking account also of a number of exceptions
• The new day counting rules for determining who or when a person has become resident in UK or who has broken residence in UK

Until or unless a statutory definition of residence appears on the statute books this is likely to remain an area of much complexity and some difficulty for tax practitioners as much as for clients!

But if we can assist please contact us for further details.