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Pre-entry planning for non-domiciliaries

Produced by Tolley in association with and Steph Carr of BDO LLP
Employment Tax
Guidance

Pre-entry planning for non-domiciliaries

Produced by Tolley in association with and Steph Carr of BDO LLP
Employment Tax
Guidance
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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.

Key points

  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 filing on the remittance basis

  2. •

    it is important to segregate bank accounts to ensure clean capital is not mixed in with income earned after an individual becomes UK resident as this then becomes a mixed fund and subject to the Mixed Fund ordering rules

  3. •

    if an individual

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  • 08 Mar 2024 09:50

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