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Abolition of the concept of domicile for tax purposes

E6.300 Abolition of the remittance basis from 6 April 2025

For the latest New Development, see ND.2764.

The commentary below describes the rules that are expected to come in from 6 April 2025. This is a summary of the key points of the changes based on the contents of Finance Bill 2025.

Prior to 6 April 2025, UK resident individuals who are not domiciled or deemed domiciled in the UK have the choice to pay tax on the remittance basis (meaning UK tax is only paid on foreign income and gains to the extent that these are brought to the UK in the tax year) or the arising basis (meaning UK tax is payable on worldwide income and gains arising in the tax year). For details of the concepts of domicile and deemed domicile, see E6.300A. For commentary on the taxation of non-domiciliaries up to 5 April 2025, see E6.324A.

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