Residence and Domicile – Tax Aspects

Speaker:  Russell Cockburn  |  CPD Hours: 6.0

Price £575 plus VAT

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This course aims to provide a thorough grounding in the principles of residence and domicile for UK tax purposes and also considers some planning opportunities available for those leaving the UK and those coming here. The course covers UK tax law and practice on residence and domicile and discusses particular planning areas such as capital gains tax. It also briefly reviews tax issues involving offshore trusts, the relevance of double tax treaties, compliance issues on arriving in or leaving the UK, any recent and relevant changes to UK tax law and practices in this increasingly complex and compliance driven area of HMRC tax practice.


Residence and Domicile and the Statutory Residence Test/Rules

  • Review of current rules
  • Automatic UK residence/Automatic overseas tests/Leavers and arrivals – UK ties?
  • HMRC practices and procedures
  • Recent and historic case law decisions of relevance
  • Available concessions and current HMRC practices
  • Possible impacts of the HMRC “Digital Taxation” project in the future?


  • Concepts of domicile of origin, choice and dependency
  • Changing domicile
  • Introduction to the remittance basis
  • The introduction of the “Deemed Domicile” rule from  April 2017

Income Tax Rules

  • Employment income
  • Self-employment income
  • Investment income
  • Leaving and arriving in the UK

Capital Gains Tax

  • Emigration rules
  • Selling UK and non-UK assets
  • Capital gains and non-resident landlords

Inheritance Tax

  • Planning issues for non-resident and non-domiciled individuals
  • Status of assets and excluded property
  • Use of trusts and timing issues


All those involved in advising on the tax issues of relevance to leaving the UK and those coming here. This course should appeal to tax advisers, accountants and tax practitioners who are asked to advise their clients or their businesses’ employees on the tax implications of leaving the UK or coming to the UK. In particular anyone who is involved regularly in helping advise or assist clients or employees with their tax affairs on leaving or arriving in the UK should benefit from this course.

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