Would IHT be payable in this scenario?

[maths]

Could I use this same list in reverse, as a guide as to the "major" actions needed to abandon a DoC,

Yes,

After having ceased the "major" ties, if I were to retain "minor" ties to the UK, such as:
• Keeping ISAs and bank accounts in the UK
• Retaining UK private pension and state pension entitlements
Is it likely that HMRC would be able to argue I failed to sever all ties to the UK, and therefore regard me as having retained my UK DoC?

HMRC will of course argue whatever they want if the monetary reward to them warrants it.

Having said this, the retention of the "minor" ties you mention above is unlikely to sustain an argument that you retained a UK DoC.

[teejaydee]

Hello maths,

Many thanks for all your advice. It's very generous of you to spend time and effort on answering these questions.

[maths]

Everyone likes the odd thank you.
Thank you.

[riccardob]

Could I use this same list in reverse, as a guide as to the "major" actions needed to abandon a DoC,

Yes,

After having ceased the "major" ties, if I were to retain "minor" ties to the UK, such as:
• Keeping ISAs and bank accounts in the UK
• Retaining UK private pension and state pension entitlements
Is it likely that HMRC would be able to argue I failed to sever all ties to the UK, and therefore regard me as having retained my UK DoC?

HMRC will of course argue whatever they want if the monetary reward to them warrants it.

Having said this, the retention of the "minor" ties you mention above is unlikely to sustain an argument that you retained a UK DoC.

Is domicile an issue that can be decided by a tax tribunal in case the tax payer disputes hmrc's position in terms of domicile?
I wonder if hmrc ever loses a case on this topic.