How to manage a domicile enquiry

Recent years have seen a significant increase in domicile enquiries. These enquiries are frequently long-running, with HMRC making repeated requests for large amounts of historic documentation in a short timeframe. Taxpayers should consider carefully the relevance of each information request and their overall strategy for managing the process. Many taxpayers have also previously obtained rulings on their domicile status. HMRC claims these are not binding following the FTT decision in Gulliver, but the position is more nuanced. If enquiries continue without resolution, taxpayers should consider applying for a closure notice.