The remittance basis—mixed funds

Produced in partnership with Alison Cartin of Taylor Wessing LLP
Practice notes

The remittance basis—mixed funds

Produced in partnership with Alison Cartin of Taylor Wessing LLP

Practice notes
imgtext

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

Finance Act 2025 (FA 2025) which received Royal Assent on 20 March 2025, implements legislation to abolish the Remittance basis of taxation and replace it with a residence-based regime, commencing on 6 April 2025. FA 2025 also replaces domicile as the key factor in establishing liability to inheritance tax. Other changes include amendment of the Rules determining excluded property status, the abolition of protected settlements status of offshore trusts, and changes to overseas workday relief.

For information on these changes, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26. See also: Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.

A UK resident non-UK domiciled individual who is taxable on the remittance basis is subject to UK tax if their foreign income and/or foreign chargeable gains are remitted to the UK. The amount of tax payable will depend on what is remitted to the

Alison Cartin
Alison Cartin

Associate Director, Taylor Wessing LLP


Alison is a Knowledge Development Lawyer for the Private Client Group, responsible for the team's know how and training needs and monitoring legal and market developments. She regularly leads both in-house and external client training events and writes materials for the Bryan Cave Leighton Paisner Tax blog and clients. Prior to becoming a Knowledge Development Lawyer in 2004, Alison advised high net worth individuals and the international wealth management institutions that serve them on the full spectrum of contentious and non-contentious private client issues. She has extensive experience advising on cross-border tax and wealth planning issues and has been involved in advising governmental and regulatory bodies on the cross-border exchange of information in tax matters and international tax agreements. She is a member of the Society of Trust & Estate Practitioners (STEP).

Powered by Lexis+®
Jurisdiction(s):
United Kingdom
Key definition:
Remittance basis definition
What does Remittance basis mean?

Taxation of an individual's foreign income and capital gains in the UK only if that income and gains are remitted, or brought to, the UK.

Popular documents