UUÂãÁÄÖ±²¥

This guidance note has been updated for the House of Lords version of the Finance Bill. Note that despite expectations that the provisions would be softened following comments made by Rachel Reeves in Davos, most of the amendments introduced during the Parliamentary process related to the trust provisions. There is no extension to the number of years covered or changes to the flat rates of tax.

Prior to 6 April 2025, UK resident individuals who were not domiciled or deemed domiciled in the UK had the choice to pay tax on:

1. •

   the remittance basis ― broadly meaning that UK tax was only paid on foreign income and gains to the extent that these were brought to the UK in the tax year, or

2. •

   the arising basis ― meaning UK tax was payable on worldwide income and gains arising in the tax year

From 6 April 2025, the remittance basis of taxation is repealed as a consequence of the abolition of the concept of domicile. This is replaced with a regime linked