Preparing for the Possibility of a Domicile Enquiry

01 August 2022
Author: Helen McGhee

Video below is an exploration who might be vulnerable to an HMRC enquiry on domicile and how best to deal with such enquiries. 


The types of non-doms most vulnerable to scrutiny:

  • “Taxpayers with a weak argument that they do not have a UK domicile of choice, but also those with a weak non-UK domicile of origin.”

Non-doms can protect themselves:

  • “It’s important to keep an up to date, running chronology of key life events and examine the impact of those life events.”
  • “Note the potential for HMRC to go back 20 years from the date of any chargeable transfer if no Inheritance Tax account has been delivered or a chargeable asset had been omitted.”
  • “Make sure you know your client before they embark on an interview.”

Finally, information requests under Schedule 36 to the Finance Act 2008:

  • “Under Schedule 36, HMRC can only ask for information that is reasonably required to check the taxpayer’s tax position.”
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