Domicile As Residence?

Examining tax changes from Finance Act 2025, this guide unpacks the shift from a domicile-based to a residence-based system and the removal of the longstanding Remittance Basis. It offers legislative text and in-depth analysis to assist advisers strategizing for mobile high-net-worth individuals. This book explains the tax consequences of the changes detailed in Part 2 of the Finance Act 2025, following the enactment of new rules announced on Budget Day 2024. These were essentially the replacement of a domicile-based system with a residence-based system and the abolition of the Remittance Basis which had been around in its current form since the beginning of the First World War. The text of the legislation is included in the publication. Each provision is analysed using the headings Overview, Relevant Legislation, Detail and Commencement. This is followed by a section on some thoughts as to how the provisions can be used for the benefit of clients. This work was originally written as a supplement to the earlier publication called Taxation of Entertainers and Sportspersons, but applies equally to personal tax advisers to mobile HNWIs.