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

It is now more than six and half years since the introduction of the deemed domicile rule for income tax and capital gains tax purposes and changes to the equivalent concept for inheritance tax purposes. In light of these rules some UK tax resident individuals who retained a non-UK domicile as a matter of common law chose to cease UK tax residence and thereby remove themselves from the scope of UK income tax and capital gains tax on a worldwide basis. For individuals who did so with effect from 6 April 2017 they have now been non-UK tax resident for six complete tax years. As a result they may be able to resume UK tax residence in circumstances where they...