Domicile As Residence?: A Guide to Part 2 Finance Act 2025

This book explains the tax consequences of the changes detailed in Part 2 of the Finance Act 2025, following the enactment of new rules announced on Budget Day 2024. These were essentially the replacement of a domicile-based system with a residence-based system and the abolition of the Remittance Basis which had been around in its current form since the beginning of the First World War. The text of the legislation is included in the publication. Each provision is analysed using the headings Overview, Relevant Legislation, Detail and Commencement. This is followed by a section on some thoughts as to how the provisions can be used for the benefit of clients. This work was originally written as a supplement to the earlier publication called Taxation of Entertainers and Sportspersons, but applies equally to personal tax advisers to mobile HNWIs.

Adrian is a highly regarded advisor with broad experience across a range of sectors and businesses. He has particular expertise in large corporate transactions and restructuring, land development, trusts, and estates, especially intangibles, as well as celebrity and HINWI tax and cross-border matters. Adrian has had a varied career in tax as a partner in two City law firms, a tenant for many years at Pump Court Tax Chambers, and an academic at Oxford and Professor of Business Law at King’ s College, London. For 13 years he was a judge of the First Tier Tax Tribunal and of the Upper Tier Tribun