Understanding your domicile status is crucial when it comes to UK tax law.

This status helps determine your liability for major UK taxes, including inheritance tax. When determining an individual's domicile of origin, it is usually based on the country their father considered his permanent home when they were born.

This concept is especially significant in the United Kingdom, as it is crucial in determining an individual's tax obligations. If an individual is considered domiciled in the UK, they are required to pay taxes on their worldwide income.

However, if they are considered non-domiciled, they may only be required to pay taxes on income earned within the UK and any foreign income brought into the country. Therefore, understanding one's domicile status is crucial regarding tax planning and compliance in the UK.

Acquiring British Citizenship

You can acquire British citizenship in a few keyways:

  • By birth - if you were born in the UK and one or both of your parents are British citizens or settled in the UK.
  • Registration - if you or your parents have strong connections to the UK, such as living there for several years.
  • Naturalisation - applying for citizenship after living in the UK for a certain period, typically 5-6 years. You must meet the good character requirement.

You will normally need to pass a Life in the UK test for registration and naturalisation. Gaining British citizenship means you hold a UK passport and have the rights of a British citizen. But how does it impact domicile?

The Definition of Domicile

In UK tax law, domicile is defined as the country an individual treats as their permanent home and to which they intend to return. As it depends on the person's long-term intentions, it can be open to interpretation by the tax authorities.

There are three types of UK domicile status:

  • Domicile of origin - established at birth, usually following that of the father.
  • Domicile of choice - chosen by an individual later in life through settling in a country and making it their permanent home without intention to leave.
  • Deemed domicile - gained through UK residence in at least 15 of the previous 20 tax years.

If you have acquired British citizenship, you must still show evidence that you have made the UK your permanent home with no plans to leave to change your domicile of origin. Just having citizenship does not automatically mean you have become UK-domiciled for tax purposes.

Does Naturalisation Change Domicile Status?

When you successfully apply to naturalise as a British citizen, you will have lived in the UK for at least 5-6 years, showing a degree of permanence. However, naturalisation alone does not determine your domicile under UK law.

Your actions and intentions regarding settling long-term must demonstrate that you consider the UK your permanent home. Factors like property ownership, family ties, bank accounts and investments may all contribute. The tax authorities will assess your individual circumstances holistically. If you move abroad for a period after obtaining British citizenship through naturalisation, you may well lose deemed UK domicile status, too.

Settled Status and Domicile

Settled status is a different immigration concept, allowing EEA or Swiss citizens to stay in the UK indefinitely after Brexit. Obtaining settled status alone does not lead to citizenship or having a right of abode in the UK.

Again, being legally settled for residency will not necessarily make you automatically UK-domiciled. Your intentions and personal circumstances must indicate you are making the UK your true, lasting home for tax domicile purposes rather than just having legal immigration status.

Starting a Family

If you start a family after naturalising or settling in the UK, it can be a factor towards altering your domicile of origin. HMRC states that starting a family is a major sign of having made a permanent home.

However, while it contributes, if other aspects like overseas homes and your time spent abroad suggest strong foreign ties, your domicile may remain different case will depend on all the relevant facts - no prescribed formula overrides intention. Where you choose to have your children educated may also indicate whether your marked, clear change of domicile is really to the UK.

Wealth and Assets

When significant assets and investments are brought onshore to the UK, it indicates you live here permanently. Applying for citizenship often entails showing sufficient resources to settle here. Again, wealth only determines domicile if actions confirm the intention to make Britain your lasting home.


Purchasing property in the UK or moving core assets like your fine art collection to Britain will underline an intention to live here long-term. But if second homes and non-UK investments remain in your name, it suggests ongoing foreign ties outside temporary UK residency. For genuine altered domicile, UK property/assets would be expected to comprise the central majority share of your holdings.


If you live and work or set up companies in the UK having acquired citizenship, it enhances the view that you are committed to building a permanent life here. By contrast, retaining or seeking employment abroad contradicts this. Roles with substantial travel or short-term UK secondments alone would not satisfy the test for a change of domicile.

Culture & Time

Immersed lifestyle integration into British culture - from community groups to language or adopting cultural norms at home - will assist arguments around altered domicile. But integration alone means little without a fundamental shift of intention evidenced through actions and commitments. Holidays or living partially integrated may show general affinity but are more limited indications of a permanent home. 

The longer someone acquires sustained trappings of home life exclusively in the UK post-naturalisation or settlement, that will reinforce arguments for a genuine change of domicile. Conversely, spending large, sustained periods abroad following immigration can undermine claims that you intend real British permanence. While continuity of time aids genuine domicile cases, longevity alone means little if initial connections remain.

Record Keeping

Records will be vital to demonstrate intentions and key milestones since any change in citizenship or residency milestone. Financial accounts tracing inflows, tax, and pension payments can affirm increasing UK investment and orientation. With robust documents confirming permanence, recollected verbal testimony long after will be able to persuade over lifelong domicile of origin.

Independent Legal Advice

With domicile interpretation often quite fluid until tested, but the tax implications serious, always consult tax advisors and solicitors specialising in tax law. When considering a potential shift in domicile, it is important to consider a variety of individual circumstances.

These may include assets, employment status, travel habits, and family situation. By conducting objective assessments that carefully consider these factors, it is possible to understand better whether a change in domicile is truly warranted. 

Demonstrating Change

Fundamentally, actions determine outcomes - the burden falls clearly on individuals with foreign domiciles of origin to produce sufficient evidence of a distinct definitive change in lifelong intentions, priorities and commitments that objectively underlines making the UK one's sole, genuine, permanent home into the future. Any lingering associations or contradictions could undermine assertions regarding your domicile.

Lifetime Transfers

One risk even following naturalisation and seemingly settling here permanently is that temporary assignments abroad might later suggest the move was not truly intended as indefinite from the outset. Since domicile is about lifelong intentions from arrival, retrospective changes weaken a claimant's position. Meticulous records are key.

Similarly, if children or assets are later transferred abroad, having weighed into a successful domicile change argument, it introduces contradiction - if the UK was your permanent home, why move core parts of your life offshore again? Transferring elements away inevitably raises doubts over original intentions. Consistent domestically retained ties are essential as evidence that the UK remains your definitive, lasting home.

Acquiring British citizenship or settling in the UK does not automatically lead to an altered tax domicile status for inheritance, income, or capital gains purposes. Beyond formal immigration, individuals must still demonstrate long-term objectives plus substantive actions that verify they have unequivocally made Britain their sole permanent home into the indefinite future.

Superficial or short-lived connections alone will not suffice to evidence this fundamental change of lifelong intentions and priorities. Independent legal advice is strongly recommended before assuming any automatic impact of citizenship or settlement on domicile.