Residence and domicile are different. Residence for Income Tax is decided for each tax year, mainly by the statutory residence test: days in the UK, ties, and the automatic tests. “Ordinary residence” has largely gone, but it can still matter for older years HMRC is looking at.
Domicile is a general-law concept, usually taken from your father at birth and hard to change without a clear decision. People can live in the UK for decades without becoming UK domiciled — and can be domiciled in a country they have never visited. From 6 April 2025 the UK moved away from domicile as the main test for taxing foreign income and gains, towards residence-based rules. HMRC still investigates older years on the old law, and they still challenge people who claimed to be non-resident or non-domiciled to keep foreign income out of UK tax.
When it surfaces in an investigation
Foreign assets only create a UK bill if the person was in the UK tax net for that year. Proving non-residence, or a historic non-domicile claim, can remove or cut a proposed assessment. HMRC also opens dedicated enquiries into people they think claimed non-residence while still living a UK life.
Companies do not have domicile. They do have residence, which can follow incorporation or central management and control. We review both the person and, where relevant, the company.
How Solaratax helps
We build a year-by-year residence analysis (travel, home, family, work) and, for earlier years, a domicile analysis. Then we either disclose on the correct basis or defend the claim HMRC is attacking.
Call 01615 314179 or email enquiries@solaratax.co.uk for a free, confidential discussion. We will not contact HMRC in your name until you instruct us to act.
Questions we are asked
Related investigations
Offshore tax investigations
CRS data, information notices and purchased leaks: HMRC already knows more about foreign accounts than most people assume.
Worldwide Disclosure Facility
A structured way to tell HMRC about offshore interests — it does not buy immunity from a criminal investigation.
Personal tax investigations
Most HMRC enquiries sit on individual tax returns — employed people, landlords, investors and the self-employed.
Talk to Solaratax
128 City Road, London, EC1V 2NX. 01615 314179. enquiries@solaratax.co.uk. Free, confidential, no obligation.
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