ÀÏ˾»úÎçÒ¹¸£Àû

Abolition of non-UK domicile basis of taxation from 6 April 2025

The non-UK domicile basis of taxation is abolished from 6 April 2025. This will affect fundamentally claims for exemptions on non-remitted income. The separate Abolition of the remittance basis from 2025/26 guidance note sets out the new and transitional rules, applying from 2025/26 onwards.

The remainder of this guidance note is written primarily with the previous rules, applying to 2024/25, in mind. There is more than one reason why it may be necessary to refer back to these earlier rules, after 5 April 2025. One example might be where an event happens in 2025/26 or later which creates tax liability, but some or all of the income was actually earned in 2024/25 or earlier (see the example provided by HMRC in ERSM165236).

In addition, it is possible employees will have established a non-UK domicile by 5 April 2025, but have yet to remit income deemed to have been earned by that date, to the UK. In such cases the remittance basis