UK tax liability on arrival in the UK

Produced by a Tolley Personal Tax expert

Personal Tax

Guidance

STOP PRESS: The remittance basis is to 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. The legislation is included in Finance Bill 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

Introduction

This note is an outline of many complex issues. It summaries the position and indicates which guidance notes will provide further information.

The starting point is that UK tax liability depends on two key factors:

•
residence
•
domicile

Residence refers to the individual’s tax status on a year by year basis. Domicile is the place which a person regards as his true home.

Up until 5 April 2013, a taxpayer’s ordinary residence status was the third key factor. Ordinary residence arises as a result of a settled purpose and so looks at the position over the longer term. The concept

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