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

The non-UK domicile (and deemed domicile) basis of taxation is abolished from 6 April 2025. This will affect fundamentally claims for overseas workday relief and, more generally, 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.

This guidance note is written primarily with the previous rules, applying to 2024/25, in mind. It is possible employees have established a non-UK domicile by 5 April 2025, but have yet to remit income earned by that date, to the UK. In such cases, the remittance basis rules may remain a consideration after 5 April 2025. However this is less likely to be a concern for those whose non-domicile status was ‘deemed’ by statute, because (as outlined below) the deemed domicile rules to 2024/25 only applied to those with relatively small sums of overseas income.

Remittance basis of taxation to 2024/25

The following represents a summary of the main considerations