UK and International Tax news

HMRC Publishes Statistics On Non Domiciled Taxpayers In The UK

Thursday 18th July 2024

HMRC has published its annual update of statistics on individuals who are non-domiciled or deemed domiciled for tax purposes.

To qualify as a non-domiciled taxpayer, an individual must have their permanent home, their ‘domicile’, outside the UK. They must also claim non-domiciled status in the UK for tax purposes in their UK SA tax returns. Deemed domiciles are formerly non-domiciled taxpayers indicating in their UK SA tax returns that they are now treated as domiciled in the UK for the purposes of income and capital gains.

The 2017 changes to end permanent non domiciled taxpayer status affected two groups, being those non-doms who were either born in the UK and UK resident since tax year ending 2018, and those UK resident for at least 15 of the 20 tax years immediately before the relevant tax year.

Key findings from this year’s publication are included below.

HMRC estimate there were 74,000 individuals claiming non domiciled status in 2022/23, up from 68,900 in 2021/22. Whilst this indicates a continued recovery in the number of non-domiciled taxpayers since the height of the COVID-19 pandemic, the numbers remain below those in 2016/17 of 91,600 and well below those reported back in 2007/08 of 137,000.

In the tax year 2022/23, HMRC estimate a combined total of at least 83,800 non-domiciled and deemed domiciled taxpayers with combined tax and NICs liabilities of £12.3bn. This is up 6% from 78,800 taxpayers and down 1% from £12.4bn in liabilities in the previous tax year. While this represents a fall in number from pre-pandemic levels, the tax and NICs liabilities from this group remain higher than prior to the pandemic.

For 2022/23, revenue from non-domiciled taxpayers was £8.9bn, and £474m or 6% higher than in 2021/22 and is at its highest level since 2016/17. Deemed domiciled taxpayers of 9.800 had UK tax liabilities of at least £3.4bn in 2022/23, representing 27% of the combined total for non-domiciled and deemed domiciled taxpayers. However, not all deemed domiciled taxpayers need indicate their status on their tax returns so their liabilities could be higher.

HMRC note that the figures for tax years 2020/21, 2021/22 and 2022/23 are provisional and subject to future updates whilst all other figures are final.

 

If you would like more information on the above, please contact Keith Rushen on 0207 486 2378.

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