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E6.324A Remittance basis—overview

For the latest New Development, see ND.2751.

The default basis of taxation for income tax and capital gains tax (CGT) for individuals is known as the 'arising basis'. Where the arising basis of taxation applies for a tax year, individuals are taxed on their worldwide taxable income deemed to arise and the chargeable gains deemed to accrue to them in the tax year.

All UK tax residents (see E6.101), whatever their domicile status, are subject to 'arising basis' tax on their UK source income and chargeable gains realised on the disposal (or deemed disposal) of UK situs assets. The 'remittance basis' is an alternative basis of UK taxation which can only be accessed by foreign domiciliaries. See E6.300A for the concept of domicile. From 6 April 2025, the remittance basis of taxation will be abolished and replaced by a new regime linked to the number of years of UK residency, see ND.2620. The remittance basis can apply to foreign income and foreign chargeable gains of such individuals. Where it does apply, such funds are only taxable