释义 |
deemed domicile When determining the liability to inheritance tax, income tax, and capital gains tax, an individual who is not domiciled in the UK is treated as if he had a UK domicile if he has been resident in the UK for more than 14 out of the 20 years prior to the occasion of charge, or was born in the UK with a UK domicile of origin and is UK-resident for the tax year of charge (or, for inheritance tax only, the previous year): see Inheritance Tax Act 1984 s 267, Income Tax Act 2007 s 835BA. This means a tax charge based on worldwide income (for inheritance tax, the worldwide estate). The rule also applies inheritance tax on a global basis for three years after an individual has lost a domicile within a constituent part of the UK. |