Inheritance Tax Act 1984 section 267

Persons treated as domiciled in United Kingdom

Section 267 sets out the rules under which a person who is not domiciled in the UK under general law may nevertheless be treated as domiciled here for inheritance tax purposes, known as "deemed domicile" or "fiscal domicile."

• Under the "three year rule," an individual who was domiciled in the UK at any time on or after 10 December 1974 and within the three calendar years before the relevant event (a death or a gift) is treated as UK-domiciled for inheritance tax.
• Under the "15 out of 20 rule," an individual who has been resident in the UK for at least 15 of the 20 tax years ending with the tax year in which the relevant event occurs, and for at least one of the four tax years ending with that tax year, is also treated as UK-domiciled, provided the residence falls on or after 10 December 1974.
• The section does not apply for the purposes of determining whether property is excluded property, and it does not override any provisions contained in double taxation conventions.
• Residence for any tax year is determined in the same way as for income tax purposes.