Glossary · UK
What is Deemed Domicile?
The rule treating long-term UK residents as UK-domiciled for tax purposes -- abolished for Income Tax and CGT from April 2025, partly retained for IHT.
Full Definition
Deemed domicile was a UK tax concept under which an individual who was not actually domiciled in the UK (under general law) was nevertheless treated as UK-domiciled for tax purposes if they met certain residence conditions. For Income Tax and Capital Gains Tax purposes, the 15-year rule applied: a person who had been UK resident in at least 15 of the previous 20 tax years was deemed domiciled in the UK from the start of the following tax year. Once deemed domiciled, the individual could no longer use the remittance basis and was taxed on worldwide income and gains in full. A separate rule deemed a person domiciled in the UK if they had a UK domicile of origin (e.g. born in the UK to a UK-domiciled father) and were UK resident, even if they had acquired a domicile of choice elsewhere. From 6 April 2025, deemed domicile for Income Tax and CGT was abolished as part of the wider non-dom reforms that introduced the FIG regime. However, IHT deemed domicile rules were retained in modified form: the 15-year rule was replaced by a 10-year rule -- a person who has been UK resident for at least 10 of the previous 20 tax years will have worldwide assets within the scope of UK IHT.