RDRM31010 - Remittance basis: introduction to the remittance basis: overview of the remittance basis regime: overview of the remittance basis regime from 6 April 2008
Source: gov.uk (2025-04-07)


From 6 April 2025

From 6 April 2025, the remittance basis of taxation has been abolished, with the concept of domicile as a relevant connecting factor in the tax system having been replaced by a system based on tax residence. From this date, all UK residents are taxed on the arising basis of assessment on their worldwide income and gains.

This means that the 2024-25 tax year was the last year for which the remittance basis could be claimed, or could apply automatically.

Any foreign income or gains that have arisen to a former remittance basis user prior to 6 April 2025 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 introduction of the remittance basis regime in 2008

Schedule 7 Finance Act 2008 introduced a package of measures for the taxation of foreign income and gains of certain UK residents on the remittance basis.

The remittance basis was an alternative basis of taxation in respect of foreign income and gains only, which was available to some UK residents who were either:
- not ordinarily resident (NOR), up to 2012-13
- not domiciled (ND) within the UK, but not deemed domiciled
These rules are found at Chapter A1 of Part 14 of ITA 2007, from section 809A to section 809Z10. There were also some consequential changes to certain sections of ITEPA 2003, ITTOIA 2005 and TCGA 1992 to reflect the new rules; further details are contained below or, where appropriate, in the relevant manuals dealing with the specific type of income or gain. There have been changes to the post-6 April 2008 remittance basis regime since it was introduced. Details of these changes are included in this chapter.

The main features of the remittance basis regime introduced on 6 April 2008:
- the introduction of a remittance basis charge (RBC) for individuals over the age of 18 who claim the remittance basis - the RBC is in addition to any tax due on any foreign income and gains remitted to the UK (refer to RDRM32200 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32200))
- the introduction of a claims mechanism to apply the remittance basis across income from employment as well as from savings and investments (relevant foreign income) and foreign chargeable gains (where applicable) - claims are made through the Self Assessment tax return (refer to RDRM32020 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32020))
- ending the entitlement to certain personal allowances and to the capital gains Annual Exempt Amount for many individuals who claim the remittance basis although there are exceptions to this (refer to RDRM32040 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32040))
- other changes to the regime included the introduction of statutory rules governing the meaning of ‘remittance’, and the identification (refer to RDRM33000 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33000)) and quantification (refer to RDRM35000 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm35000)) of such remittances for UK tax purposes, and a series of exemptions to these statutory rules covering certain types of remittance, for example, allowing certain personal items, or items such as works of art in the UK for public display or repair to be brought into the UK without creating a taxable remittance (refer to RDRM34000 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm34000)) - from 2012-2013 new rules were introduced which allow foreign income and gains used to make a qualifying investment (business investment relief - refer to RDRM34300 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm34300)) and remittances arising from the sale of exempt property in the UK (refer to RDRM34240 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm34240)) not to be treated as remitted