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 simp;ly say that the amount of tax at stake is only one factor in deciding whether to open an enquiry.