From 6 April 2017, anyone who has been a resident in the UK for 15 of the previous 20 tax years will be deemed to have a UK domicile where they do not already have one. This will apply for all tax purposes and will replace the current deemed domicile rule for inheritance tax purposes whereby an individual is deemed to be domiciled in the UK where he or she has been UK-resident for 17 of the previous 20 tax years.
The introduction of the deemed domicile will mean that the option to be taxed on the remittance basis on payment of the remittance basis charge will from 6 April 2017 no longer be available to those who have been resident in the UK for tax purposes for 15 of the last 20 tax years. The remittance basis is only available to those who are not UK domiciled or who are not deemed to be so domiciled. Consequently, the higher rate of the remittance basis charge (£90,000 for those resident in at least 17 of the previous 20 tax years) will cease to apply from 6 April 2017.
Anyone caught by the new rule will need to review their residence position.