HM Revenue & Customs (HMRC) has issued a revised version of its guidance on residence and domicile –"HMRC 6 – Residence, Domicile and the Remittance Basis". The main changes relate to residence –indeed the section on domicile is unchanged. HMRC states that"the wording used in the previous version of HMRC 6 may be used for any tax liability that arises before 5 April 2011" and that, in its view, the revision has not"altered the current position in the majority of cases". HMRC's emphasis continues to be on the need to show a distinct break from the UK in order to cease to be resident under the permanent departure test.

However, a number of areas in relation to residency remain unclear. It is therefore important for anyone who has recently left the UK to review their position in light of these changes and clearly it will be important for anyone considering leaving to plan very carefully. There are also specific issues for people leaving the UK to work abroad and similarly these situations should be reviewed carefully.