Domicile and Residence

Abstract

After protracted consultations on fundamental aspects of the UK taxation of non-residents and non-domiciliaries, which have spanned more than three years, FA 2013 will contain the UK’s first comprehensive statutory regime for determining resident status of individuals for tax purposes. The propos- als were originally intended to operate from 6 April 2012, but were post-poned to commence on 6 April 2013. As successive drafts became available, we have kept readers advised of the latest known key factors (17.5.1), which were expected to come into effect between publication dates, such that our 2012–13 edition presented a summary of the proposals as published on 21 June 2012 (2011–12 edition – on 17 June 2011). As we go to press, the new regime is in force, FB 2013 is before Parliament and in May 2013 HMRC published a 101 page ‘Guidance Note – RDR3’ and ‘Overseas Workday Relief – RDR4’ which set out their views on numerous detailed aspects.