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Domicile enquiries: a new approach

HMRC has admitted that guidance setting out when it will consider a person’s domicile and decide whether to make a determination of inheritance tax based on that domicile has not  been working well for HMRC or taxpayers.

The department is adopting ‘a wider risk-based approach’ and has published revised guidance in Revenue & Customs Brief 34/10 available via which replaces Brief 17/09 issued last year.

HMRC will now consider opening an enquiry where domicile could be an issue or making a determination of IHT in such cases only where there is ‘a significant risk of loss of UK tax’.

A range of factors will be used in assessing that risk including whether the amount of tax at risk – including IHT – is significant. HMRC does not consider it appropriate to state an amount of tax that would be considered significant...

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