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Deemed domicile ― rebasing for capital gains tax (2017/18 to 2024/25)


Produced by a Tolley Personal Tax expert
Personal Tax
Guidance
tag-icon Autumn Budget 2024

Deemed domicile ― rebasing for capital gains tax (2017/18 to 2024/25)


Produced by a Tolley Personal Tax expert
Personal Tax
Guidance
tag-icon Autumn Budget 2024
imgtext

STOP PRESS: At Spring Budget 2024, the Chancellor announced that the remittance basis would be abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

Introduction

Fundamental changes to the tax regime for non-domiciled individuals were introduced from 6 April 2017. They involve deeming an individual to be UK domiciled for tax purposes even though they may be non-domiciled in the UK under general law. The rules apply for income tax, CGT and IHT.

Non-domiciliaries:

  1. •

    caught by the deemed domicile 15-year rule in 2017/18 may be able to rebase their foreign chargeable assets for CGT purposes as at 5 April 2017

  2. •

    had a one-off opportunity to clean up existing mixed funds, see the Remittance basis ― mixed fund cleansing (April 2017 to April 2019) guidance

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  • 01 Nov 2024 05:51

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