Domicile – new HMRC guidance
HMRC have issued new guidance explaining a change to the circumstances in which they will consider an individual’s domicile status for inheritence tax purposes.
HMRC intend to use a wider risk-based approach when deciding whether to investigate an individual’s domicile and whether to make a determination of inheritance tax based on that.
Going forward, HMRC will consider opening an enquiry where domicile could be an issue, or making a determination of inheritance tax in such cases, only where there is a significant risk of loss of UK tax.
HMRC have not provided any further information as to what amount of tax would be considered significant. They simply say that the amount of tax at stake is only one factor in deciding whether to open an enquiry.