RDRM32010 - Remittance Basis: Accessing the remittance basis: Claiming the remittance basis up to 5 April 2025: Who can claim - status conditions
Source: gov.uk (2025-04-07)


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 guidance in this section only applies to tax years up to and including the 2024-25 tax year and remains for reference purposes only.

‘Exempt employments’ (#IDAWGEDG)

Temporary non-residents (#IDABCEDG)

Relevant Foreign Income (#IDABDEDG)

Foreign chargeable gains (#IDAOEEDG)

Section809B(1) sets out the conditions for the remittance basis to apply to an individual.

These conditions are that the individual:
- is resident in the UK in the year
- is not domiciled in the UK in the year or, up to and including 2012-2013, is not ordinarily resident in the UK in the year
- makes a claim under ITA07/s809B for the year
Note 1 - the concept of ordinarily resident was removed from the Taxes Act from 2013-2014 onwards. Up to and including 2012-2013 an individual who was UK domiciled but not ordinarily resident could claim the remittance basis. From 2013-2014 onwards access to the remittance basis is restricted to individuals who are not domiciled in the UK only.

Note 2 - individuals who are deemed domiciled in the UK - which applies from 6 April 2017 - cannot claim the remittance basis.

Up to 2012-2013 there were differences in how the remittance basis applied, depending on whether the remittance basis claim was made in connection with the individual's residence or domicile status, to an individual's foreign income or gains (refer to RDRM31040 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm31040) What income and gains does the remittance basis apply to).

As a condition of making the claim under s809B(1), the claim itself must include a statement to the effect that the taxpayer making the claim is not domiciled in the UK, or (up to 2012-2013) is not ordinarily resident in the UK. This statement is an integral part of the claim process (refer to RDRM32020 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32020) Making a claim).

‘Exempt employments’

There is special legislation that provides that the employment income of certain employees who work for certain organisations or government agencies is exempt from UK tax. These are usually European or International agencies, and the employee will be aware of their tax status in relation to their employment income from that institution. The extent and nature of the exemption varies from institution to institution, and sometimes depends on the role undertaken by that employee or officer. Usually such employees remain liable to UK tax on income from other sources in the same way as any other UK resident.

If these employees wish to use the remittance basis in respect of their other income and gains they will be required to claim the remittance basis in the same way as any other user. Any ‘exempt’ employment income may be ignored in computing levels of UK or foreign income or gains.

The special provisions usually provide an exemption from the UK tax effects of an employee’s residence status only for their specific emoluments, that is, the exemption simply removes the liability to UK tax, not the underlying UK residence status. Each year in which the employee is regarded as resident in the UK will count as a year of residence. Also, employees will lose their personal allowances and Annual Exempt Amount and will be subject to the £30,000 or £60,000 remittance basis charge as well (unless they are below the £2,000 threshold RDRM32135 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32135) ).

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Temporary non-residents

The remittance basis applies only to UK resident individuals.

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Relevant Foreign Income

However, there are certain provisions at ITTOIA05/s832A in respect of remittances of relevant foreign income in years when an individual is not resident, which might have to be considered for individuals who may be deemed to have been temporarily non-resident upon their return to the UK. For full details refer to RDRM32500 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32500) Temporary Non-Residents.

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Foreign chargeable gains

There are also provisions at TCGA92/s10A in respect of remittances of foreign chargeable gains in years when an individual is not resident which might have to be considered for individuals who may be deemed to have been temporarily non-resident upon their return to the UK. For full details of these rules refer to the Capital Gains Manual.