RDRM24050 | Domicile: Illustrative Scenarios: Mr G

From 6 April 2025, the concept of domicile as a relevant connecting factor in the tax system has been replaced by a system based on tax residence. This guidance remains for reference purposes only.

In retirement G and his wife went to live in Italy. They comprehensively severed their links with the UK and intended to remain in Italy indefinitely. Two years after settling in Italy G died.

Although he was domiciled in Italy at the time of his death, for both UK common law and Italian law purposes, G fell within the scope of section 267 IHTA 1984 and so had a ‘deemed domicile’ in the UK. In interpreting the provisions of the relevant UK/Italy Double Taxation Convention, and only for such purposes, the ‘deemed domicile’ legislation is to be ignored.

Refer to RDRM20040.