IHTM13034 - Domicile: Liaison Arrangements with Centre for Non-Residents and HMIT

It is important that negotiation and agreement with a taxpayer about domicile and residence or ordinary residence does not prejudice the interests of the Centre for Non-Residents (Residence Advice & Liabilities), Bootle, who give rulings on domicile and residence for IT and CGT or run counter to any previous agreement between the taxpayer and HMRC.

If there is no note of any previous agreement or if the circumstances dictate that the question be investigated afresh, Technical Group will, if necessary, negotiate with CNR and/or HMIT before discussing or agreeing domicile or residence with the taxpayer.

Note that Income Tax cannot be assessed more than three years after the date of death. So when an non-UK domicile is claimed but not agreed for a taxpayer who was normally resident in the UK, CNR must be notified by us either when a UK domicile is conceded by the taxpayer or on the first BU date if the domicile has not been settled.

We must include

• the name, address and date of death of the deceased
• the names and addresses of the PR’s
• an indication of the likely value of the estate
• a brief note of the domicile position; and
• if known, the deceased’s GCD and that district’s reference.