This site provides comprehensive information about:
- Taxation of foreign domiciliaries
- Taxation of non-residents on UK income and assets
- Taxation of UK residents on foreign income and assets
- Other topics arising in this context, including tax avoidance, and disclosure and compliance
It is the online version of Taxation of Non-Residents and Foreign Domiciliaries by James Kessler QC.
Non-dom Policy & Avoidance:
Domicile & Residence:
- 4 Domicile
- 12 Exit Taxes
Income Tax: Principles & Remittance Basis:
- 20 Mixed Funds
Income by Category:
- 23 Performers
- 36 PAYE
IT Avoidance Codes:
Capital Gains Tax:
- 62 Sub-Funds
- 68 Unit Trusts
- 83 Partnerships
Topics Affecting More Than One Tax:
- 93A Cryptoassets
Double Taxation Agreements IT/CGT:
Double Taxation Agreements: IHT:
- 115 IHT DTA: USA
- 119 Claims
- 122 Penalties
- 128 Money Laundering
Words & Concepts:
Construction of Statutes:
New 2022/23 edition
The new 2022/23 edition of Taxation of Non-Residents and Foreign Domiciliaries is now available online and and available in paper form.
Licences for the 2021/22 edition will no longer be valid from 6 April 2022.
If you are an academic or other non-tax practitioner who wants access for research purposes, contact James Kessler
How to login
Most of this site requires you to login. To obtain a login licence:
You may purchase a single or multiple user licence: To obtain these contact the publishers.
Without logging in, you can access:
You enter this site once you have registered and logged in by clicking on the index on the left, or you can search the text.
You need to register for the current edition. Registration for an earlier edition is no longer valid.
Users can also contribute to the text and if you can add anything, or spot anything that needs to be corrected, please do! A copy of the next edition of the book will be given to the user who makes the most edits. User contributions are reviewed by Rebecca Sheldon.
If you want further advice
If you do not find the answer to your question here, or if you want advice on which you can legally rely, you may instruct James Kessler QC or other members of his chambers to advise. See How to instruct James Kessler QC.
There are archive editions for years since 2003/04. These will be useful to investigate the tax position in earlier years, but the current edition will generally be the best starting point, as that has been written in the light of current HMRC guidance, and further thought and research.
Note: You may need to input your current log-in name and password to access the archive editions, even if you are already logged in to the site for the current online edition.
If you have technical problems, or problems logging in, click here
To contact James Kessler QC click here
To contact Rebecca Sheldon, who reviews online contributions, click here
For multiple user licences, or to install on a firm's intranet, contact the publishers.
TFD Resource Archive
To access this TFD reference material, click here TFD Resource Archive