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Resetting the clock and the six-year itch: non-domiciliaries resuming UK tax residence

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The changes to the taxation of non-UK domiciled individuals introduced with effect from April 2017 caused many to rethink their connections with the UK. For those who departed, the framework of the legislation allows for the ‘re-setting’ of the domicile clock thus permitting a return to the UK with a favourable tax profile. But is this possible in reality? It is not just a matter of years of non-residence, there are the underlying principles of the common law concept of domicile to navigate. If individuals do decide to return, the temporary non-residence rules can defeat the best planning for new non-taxable sources of funding. The future of the remittance basis is also in doubt ahead of the forthcoming general election.

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