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Introduction

The concept of deemed domicile was introduced for income tax and capital gains tax (CGT) from 2017/18 onwards. As part of these provisions, non-domiciliaries:

1. •

   caught by the deemed domicile 15-year rule in 2017/18 may be able to rebase their foreign chargeable assets for CGT purposes as at 5 April 2017, see the Deemed domicile ― rebasing for capital gains tax (2017/18 onwards) guidance note

2. •

   had a one-off opportunity to clean up existing mixed funds between 6 April 2017 and 5 April 2019

For the details of the deemed domicile rules, see the Deemed domicile for income tax and capital gains tax (2017/18 to 2024/25) guidance note.

Once an individual becomes deemed domiciled for income tax and CGT, they are taxed on the arising basis. Due to the way the mixed fund rules work, non-domiciliaries approaching the date on which they become deemed domicile would find it expensive to reorganise their affairs. The Government acknowledged these consequences, stating:

‘...an individual with a mixed fund will find it difficult