Friday, 29 March 2013

The Strange Case of Dr Watson’s ‘Deemed Domicile’

Watson’s return to UK

Dr Watson returned from India after seeing service in the second Anglo-Afgan war where he was wounded and then suffering enteric fever landed at Tilbury docks on 5 January 1881. No longer able to stay in India, his domicile of choice, Watson rents rooms at 221b Baker Street with a Sherlock Holmes. Dr Watson has various houses in India which is the custom there and he enjoys substantial dividends from Peninsular & Oriental Steam Navigation Company shares. The shares are quoted in London. Dr Watson has the ultimate intention of returning permanently to India, his domicile of choice, but has remained in the UK because of his illness and subsequent adventures with Holmes. He receives a strange letter on 26 April 1897 whilst at 221b Baker Street from Her Majesty’s Revenue and Customs (Queen Victoria) suggesting he is now to be categorised as ‘deemed domicile’. He passes the letter to Sherlock Holmes who states ‘Watson, I am minded to ignore this strange letter but something perturbs me about it!’

The Crime
Holmes deduces that if Dr Watson is considered ‘deemed domicile’ in the UK despite his claim for domicile of choice in India this would mean his Indian assets and Peninsular shares will be taxed on his death at 40%. Similarly if he returns to India and dies within 3 years of leaving the UK he will also be taxed on the value of those assets at the date of his demise. The clues Holmes has turned up are that Watson returned to the UK on 5 January 1881 and was classed as resident for income tax purposes from that date i.e. tax year 1880/81. This income tax treatment also affects inheritance tax too as the income tax residence rules impact on inheritance tax. So even though Watson arrived at Tilbury Docks on 5 January 1881 towards the end of the tax year i.e. 5 April 1881 he was classed as resident for income tax and also inheritance tax for the whole of the year 1880/81. As the years passed Watson did not know this until the strange letter was received on 26 April 1897 from Her Majesty’s Revenue and Customs (Queen Victoria) suggesting he is now likely to be categorised as ‘deemed domicile’. What perplexes Holmes is that the letter mentions Watson’s residence in UK as being 17 years out of the last 20 years of assessment. However, Watson arrived in the UK on 5 January 1881 and it is now 26 April 1897 some 16 years 4 months later not 17 years!

The clues
So how is it Dr Watson can be classed as deemed domicile in the UK when the legislation says 17 out of the last 20 years? Holmes researches the legislation:
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—
(a)                   he was domiciled in the United Kingdom within the three years immediately preceding the relevant time, or
(b)                   he was resident in the United Kingdom in not less than seventeen of the twenty years of assessment ending with the year of assessment in which the relevant time falls.
(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.

Holmes deduces that the words ‘years of assessment’ means tax years i.e. 6 April to the following 5 April and not actual years spent in the UK which in Watson’s case is some 16 years 4 months. Hence, the deemed domicile and attaching tax consequences. Also, the word resident means that when Dr Watson joined Holmes at 221b Baker Street in January 1881 it was his intention to settle in London having signed a sub-lease to lodge with Holmes. This fact means that Watson was resident for income tax purposes from his date of arrival and thereby subject to inheritance domicile tax by implication for the whole of the 1880/81 tax year although he had been in India for most of the year. Holmes wonders if he has missed any salient points?

The conclusions
‘Deemed domicile’ in the UK for inheritance tax purposes can apply inheritance tax to anyone’s worldwide assets if they are resident in the UK for seventeen out of the last twenty tax years. Leaving the UK after 22 April in the tax year April may mean that UK residence applies for that year although this depends on certain connecting factors but in Dr Watson’s case his circumstances may preclude this as he has the maximum number of connecting factors meaning his ‘arriver’ status at Tilbury Docks and ‘leaver’ status at departure from UK at the end of his residence there is limited to less than 46 and 16 days respectively. Even if Watson was to return to India straight away then for income tax purposes he would be classed under the new residence rules as a ‘leaver’ and just 16 days in the UK would make him resident for income tax because of his connecting factors. Consequently he would be treated as resident for inheritance tax too! Holmes muses that had the boat bringing Dr Watson been delayed in Cape Town for six weeks due to storms, a common occurrence at that time, and his arrival had been on 26 February 1881 his first year of residence would have been 1881/82 and not 1880/81 because he had less than 46 days in the UK. Therefore Dr Watson’s continued presence and personal connections in the UK since his arrival do point to him being ‘deemed domicile’ from 26 April 1897.

Clueless?
Holmes admits defeat and contacts his trusty old tax accountant Jon Golding and recounts Dr Watson’s situation to him. Golding mentions to Holmes that under s 267(2) above the UK’s deemed domicile rule is ignored where there is an overriding Double Tax Treaty relevant to estate taxes. This would preclude UK estate duty/inheritance tax being applied on Dr Watson’s overseas assets at the time of his death as long as he is domiciled in a country that has such an agreement. However, Watson’s Peninsular & Oriental Steam Navigation Company shares would still be taxed in the UK. Golding finds a rare edition of Article III of the UK/India 1956 (SI 1956 No 998) treaty on his bookshelf which says:
‘Duty shall not be imposed in Great Britain on the death of a person who was not domiciled at the time of his death in any part of Great Britain but was domiciled in some part of India on any property situate outside Great Britain…’

Golding also states that India repealed its Estate duty law and therefore no assets would be subject to estate taxes in India on Dr Watson’s death if he was to be domiciled there by choice.

As an aside Golding mentions that there are also such treaties with Italy, Pakistan and France. The UK/Italian Treaty of 1966 (SI 1968 No 304) also similarly states if the deceased was domiciled in Italy then such property not located in the UK will be exempt from UK inheritance tax. Holmes leaves his accountant’s office with this bit of useful information for future cases.

The accountant’s conclusion of this case is that should Dr Watson should return for to India immediately or in the future and resurrect his Indian domicile and then treaty relief would preclude the application of the deemed domicile rule. Holmes decides that Dr Watson’s services to him are more important than the potential saving in tax and says nothing!  
Apologies to Sir Arthur Conan Doyle.

Jon Golding ATT TEP former tax author is UK Tax and Trusts adviser with PI Ltd, Kuala Lumpur. Contact jongoldingtax@gmail.com Tel: +6012 287 1550 

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