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Key points

The non-UK 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.

The remainder of this guidance note is written primarily with the previous rules, applying to 2024/25, in mind. However 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 will remain a consideration after 5 April 2025.

As regards the general position to 2024/25:

1. •

   assets and funds earned prior to becoming UK tax resident are considered clean capital (see definition below under Segregation of bank accounts ― splitting funds from different sources) and cannot give rise to a tax charge in the UK even if remitted when an individual is UK tax resident and