[IHTM13024] IHTM13024 – Change of Domicile: Deemed Domicile
Even if a person is domiciled outside the UK under common law, two special rules apply to those who have emigrated from the UK or to those who have been resident in the UK for tax purposes for many years (IHTA84/S267). If either rule applies then, in most cases, we treat them as domiciled within the UK for Inheritance Tax purposes. So the definition of domicile for Inheritance Tax includes deemed domicile. For all other purposes, for example, succession, the general law applies. In addition, IHTA/S267A allows someone who is:
•married or in a civil partnership and
•not domiciled in the UK
to elect to be treated as if they were domiciled in the UK (IHTM13040).