Malcolm Finney looks at deemed domiciled status following changes introduced in F(No 2)A 2017.
Prior to changes introduced in F(No 2)A 2017, it was not possible for an individual to be categorised as deemed domiciled for income tax or capital gains tax (CGT) purposes, albeit an individual could be so categorised for inheritance tax (IHT) purposes.
From 6 April 2017 (under ITA 2007, s 835BA), deemed domicile status applies for both income tax and CGT purposes.
UK domicile of origin and born in the UK
For present purposes the aspect of the new rules of particular interest is that which applies to individuals who were born with a UK domicile of origin and who have acquired a non-UK domicile of choice for example by residing overseas with an intention to remain overseas, sometimes referred
