RDRM31110 - Remittance Basis: Introduction to the Remittance Basis: Foreign Income and Gains: Foreign Income and Gains - overview
Source: gov.uk (2025-04-07)


Chapter A1 Part 14 ITA 2007 applies to foreign income or gains that are remitted or are treated as having been remitted to the UK if the remittance basis of taxation applied to an individual for a tax year under sections 809B, 809D and 809E of that chapter.

From 6 April 2025 it is not possible to use the remittance basis of taxation, however, any foreign income or gains that have arisen to a former remittance basis user prior to this date will continue to be taxed at the usual tax rates if they are remitted to the UK on or after 6 April 2025, subject to any amounts designated under the temporary repatriation facility (TRF) – see RDRM71000 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm71000).

The pages in this section provide guidance for former remittance basis users who continue to remit pre-6 April 2025 foreign income and gains.

Under section 809F ITA 2007, the remittance basis of taxation applied to:
- relevant foreign earnings RDRM31120 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm31120) - sections 22 or 26 ITEPA 2003 (note: relevant foreign earnings meant different things depending on the individual’s ordinary residence and domicile status)
- foreign specific employment income - chapter 5A of Part 2 RDRM31130 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm31130) and part 7 of ITEPA 2003 RDRM31125 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm31125)
- relevant foreign income RDRM31140 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm31140) - section 830 ITTOIA 2005
- foreign chargeable gains RDRM31170 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm31170) - schedule 1A TCGA 1992
Nominated income or gains

Income or gains nominated by the individual for the purposes of the remittance basis charge (refer to RDRM32320 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32320) - Making a nomination) were not taxed on the remittance basis; instead they were taxed on the arising basis. Because tax, in the form of the remittance basis charge, is paid on nominated income or gains on the arising basis in the process of paying the charge, UK tax has already been paid on any nominated income or gains. So when these nominated income or gains are ‘remitted’ to the UK there is no further tax due (section 809F(6)).

However, there are some special ‘ordering’ rules that apply in certain circumstances when nominated income or gains are remitted, which broadly apply if the individual has other foreign income or gains subject to the remittance basis. These rules are complex, but broadly they result in nominated income or gains being treated as the last of the individual’s foreign income or gains to be remitted, even if this is not actually the case. You should refer to RDRM35100 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm35100) - Remittances of nominated income and gains for more information.

Foreign income or gains not covered by remittance basis

There are some items of foreign income and gains that the remittance basis did not apply to, or which have their own rules which interacted with the remittance rules covered in this manual. For example: gains under a policy of life assurance, life annuity or on a capital redemption policy. These were always taxable on the full amount on the arising basis, irrespective of domicile or residence status. Refer to Chapter 9 of Part 4 of ITTOIA 2005 for details, including relief for periods of non-residence.