Domicile as Residence? A Guide to Part 2 Finance Act 2025

Taxation

Domicile as Residence? A Guide to Part 2 Finance Act 2025

By Adrian Shipwright
Spiramus Press Ltd December 2025

Specifications

ISBN-13
9781913507886
Publisher
Spiramus Press Ltd
Publication
December 2025
Format
Paperback
Jurisdiction
U.K. ? Countri(es) for reference only

Details

This book explains the tax consequences of the changes detailed in Part 2 of the Finance Act 2025, following the enactment of new rules announced on Budget Day 2024.

These were essentially the replacement of a domicile-based system with a residence-based system and the abolition of the Remittance Basis which had been around in its current form since the beginning of the First World War.

The text of the legislation is included in the publication. Each provision is analysed using the headings Overview, Relevant Legislation, Detail and Commencement. This is followed by a section on some thoughts as to how the provisions can be used for the benefit of clients.

This work was originally written as a supplement to the earlier publication called Taxation of Entertainers and Sportspersons, but applies equally to personal tax advisers to mobile HNWIs.

Table of Contents

Preface
1.
The New Residence Based Regime after Finance Act 2025
2.
Specifics: Replacement of Special Rules Relating to “Domicile
3.
Trusts: connected amendments, transitional provision etc.
4.
Inheritance Tax
Appendix 2: ANNEXE
Appendix 3: Inland Revenue Pamphlet IR 20 Extracts
Appendix 4: Some Relevant Definitions
5.
Relief for New Residents for Foreign Gains
Appendix 5: Table of some relevant definitions
6.
Some first thoughts, and possibilities
Appendix 6: Some questions for clients?
Appendix 7: Table of Situs of Assets
Appendix 8: Jurisdiction Table
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