Domicile and citizenship - losing UK domicile

If you have a UK domicile of origin (ie you were born to UK domiciled parents) in order to lose UK domicile, you would need to establish an overseas country as a new domicile of choice. A domicile of choice involves both fact and intention. Therefore you would need to establish firstly your 'sole or chief' residence abroad, and in addition would need to show an intention to remain there for the rest of your days unless and until something occurred to make you change your mind. It would be important that you had lost your UK residence status. If you made visits to the UK in excess of 90 days per year you would remain a UK resident and the Revenue would be unlikely to accept that you had established a domicile of choice overseas. Your citizenship, whilst taken into account is not conclusive, and any statements made by you, although persuasive would not settle your domicile. The best option to avoid a UK domicile is to purchase and occupy a new home overseas. Provided you had no available accomodation in the UK,you clearly established a new life overseas and avoided UK residence you should cease to be UK domiciled. Issues such as having an overseas will, being buried overseas, having overseas investments, relinquishing UK clubs etc would all be relevant. If you relinquished UK citizenship and acquired an overseas citizenship you would still need to limit UK visits to avoid being subject to UK Inheritance tax on your worldwide estate.