RDRM22110 - Domicile: Categories of domicile: Domicile of origin - Adoption

From 6 April 2025, the concept of domicile as a relevant connecting factor in the tax system has been replaced by a system based on tax residence. This guidance remains for reference purposes only.


The Adoption and Children Act 2002 provides that an adopted child is regarded as having acquired a new domicile of origin from the relevant adoptive parent; this will be the domicile of his adoptive father or, if there is no adoptive father his adoptive mother, at the time of his adoption.

This is the main circumstance in which a domicile of origin may change from that acquired at birth. This is because an adopted child is treated in law as ‘born’ to his adoptive mother and/or father.