Currently non-UK domiciliary individuals only pay tax on their foreign income/capital to the extent that they remit the income (and capital gains) to the UK. It is said that this loophole can be exploited for long periods of time. According to reports in the Financial Times (15 March) it is now being proposed that these benefits will only pertain for a much shorter period, the article reports four years.
The UK taxes individuals by reference to a combination of residential and domiciliary status. The latter is based on where a person regards his permanent home to be. There are three aspects to this concept: a domicile of origin, usually inherited from one’s father, a domicile of choice and a domicile by operation of law.
