As the non-dom rules have changed several times over the years, seeking professional advice regularly has become essential.

Indeed, nowadays most banks and trust companies will not carry out any planning on the basis of domicile until they are in receipt of professional advice confirming their client’s domicile status.

Domicile is not just a concept that is relevant for the taxation of income and gains, it is also relevant in determining whether an individual’s non-UK assets are within the scope of UK inheritance tax. Once an individual is deemed domiciled in the UK, their worldwide assets fall within the scope of UK IHT.

India, as well as Italy and Pakistan, are party to an advantageous IHT treaty with the UK. This is not some sort of new loophole, but a treaty that was concluded between the UK and India in 1956.

In some cases, long-term UK-resident Indian non-doms who are deemed domiciled in the UK can opt for their non-UK assets to fall outside the scope of UK IHT on death.

While advice should be taken before relying on these treaties, this planning can be beneficial for many families from India and Pakistan with non-UK assets, not just billionaires.

Dhana Sabanathan is a partner at Winckworth Sherwood