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UK resident individuals who are not domiciled or deemed domiciled in the UK currently have the choice to pay tax on the remittance basis (meaning UK tax is only paid on foreign income and gains to the extent that these are brought to the UK in the tax year) or the arising basis (meaning UK tax is payable on worldwide income and gains arising in the tax year).

From 6 April 2025, the remittance basis of taxation is expected to be abolished. This is to be replaced by a new regime linked to the number of years of UK residency called the ‘foreign income and gains’ regime (FIG). This regime is to be open to anyone who meets the residence conditions, including those who would otherwise be considered to be UK domiciled.

However, that does not mean the remittance basis rules can be forgotten, as advisers will still need to know and be able to apply the current rules for previously unremitted foreign income and gains that are remitted on or after 6 April