SolvedRDRM24170 | Domicile: Illustrative Scenarios: Mr W
From HM Revenue & Customs · Remittance Basis and Domicile Manual
From 6 April 2025, the concept of domicile as a relevant connecting factor in the tax system has been replaced by a system based on tax residence.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.
W was born in England. At the age of twenty-five he emigrated to Portugal with the intention of remaining there indefinitely.
W comprehensively severed his links with England and acquired a domicile of choice in Portugal. After a few years W’s personal circumstances changed and he decided that he no longer wished to live in Portugal indefinitely. At that point W was still domiciled in Portugal, as he had changed his ‘intention’ but not his ‘residence’.
Some time later W left Portugal with no intention of returning. He lost his domicile of choice in Portugal at that point. He spent the next few years taking short-term contracts around the world, to indulge his sky-diving hobby. As W has not yet formed the intention of living indefinitely in another territory, his domicile of origin in England and Wales has revived.