Domicile and remittance

Prior to 6 April 2025, individuals who were resident in the UK but domiciled outside the UK could claim the remittance basis of taxation on their foreign income and gains (FIG). The remittance basis meant that an individual’s FIG would be charged to UK income tax or capital gains tax (CGT) if and to the extent that they were remitted (brought into) the UK, but not if they remained overseas or if a relief applied. The foreign assets of a UK resident, non-UK domiciled individual were (subject to some exceptions) outside the scope of UK inheritance tax (IHT).

In Finance Act 2025 (FA 2025), the government abolished the concept of domicile and the remittance basis. With effect from 6 April 2025, if an individual is resident in the UK then, subject to transitional rules and the terms of any applicable double tax treaty, their FIG (as well as their UK income and gains) are charged to UK income tax or CGT and their foreign assets (as well as their UK assets) are subject to UK IHT.

Nevertheless, the concepts of domicile and remittance remain