PART IX MISCELLANEOUS AND SUPPLEMENTARY

Miscellaneous

267 Persons treated as domiciled in United Kingdom.

1

A person not domiciled in the United Kingdom at any time (in this section referred to as “the relevant time”) shall be treated for the purposes of this Act as domiciled in the United Kingdom (and not elsewhere) at the relevant time if—

C1a

he was domiciled in the United Kingdom within the three years immediately preceding the relevant time, F7...

F6aa

he is a formerly domiciled resident for the tax year in which the relevant time falls (“the relevant tax year”), or

F2b

he was resident in the United Kingdom—

i

for at least fifteen of the twenty tax years immediately preceding the relevant tax year, and

ii

for at least one of the four tax years ending with the relevant tax year.

2

Subsection (1) above shall not apply for the purposes of section 6(2) or (3) or 48(4) above and shall not affect the interpretation of any such provision as is mentioned in section 158(6) above.

F33

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4

For the purposes of this section the question whether a person was resident in the United Kingdom F4for any tax year shall be determined as for the purposes of income tax F1. . ..

F55

In determining for the purposes of this section whether a person is, or at any time was, domiciled in the United Kingdom, sections 267ZA and 267ZB are to be ignored.