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IHTM13021 | Change of Domicile: Domicile of origin, choice and dependence

From HM Revenue & Customs · Inheritance Tax Manual

From 6 April 2025, for inheritance tax purposes, domicile is replaced by long-term UK residence and you can find details of these rules at IHTM47000.

There are three types of common law domicile:

  • domicile of origin,

  • domicile of dependence

  • domicile of choice

These different types of domicile are explained in detail in the Residence Domicile and Remittance Basis Manual (RDRM) (HMRC website).

For Inheritance Tax purposes you must always remember that the deemed domicile provisions of IHTA84/S267 (IHTM13024) may also apply.