Evaluation of the 2017 change to UK Deemed domicile policy
This report examines the response of taxpayers who have been 'deemed domiciled' in the UK due to the 2017 Deemed Domicile reforms to the non-dom tax regime.
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This evaluation report looks at both the Exchequer revenue change and mobility response of deemed domiciled taxpayers due to the 2017 Deemed Domicile reforms to end permanent non-dom status. Deemed domiciled tax status applies to at least 9,000 taxpayers per year and this number is increasing every year.
It finds that the majority of taxpayers affected by the reforms did remain in the UK, and that they paid more tax on average since becoming deemed domiciled. The increase in tax paid has been driven by those who have historically paid relatively more tax paying an even greater amount of tax.
Deemed domiciled taxpayers are contributing more than £3 billion per annum to the UK in taxes and National Insurance contributions (NICs). Condition B deemed domiciled taxpayers paid more tax on average since becoming deemed domiciled. Around £1 billion of that (in each of tax years ending 2019 and 2020) was additional revenue collected above and beyond what we might have expected had the deeming reforms not taken place.