Automatic remittance basis

Produced by Tolley in association with

Employment Tax

Guidance

Abolition of non-UK domicile basis of taxation from 6 April 2025

The non-UK domicile (and deemed domicile) basis of taxation is abolished from 6 April 2025. This will affect fundamentally claims for overseas workday relief and, more generally, exemptions on non-remitted income. The separate Abolition of the remittance basis from 2025/26 guidance note sets out the new and transitional rules, applying from 2025/26 onwards.

This guidance note is written primarily with the previous rules, applying to 2024/25, in mind. It is possible employees have established a non-UK domicile by 5 April 2025, but have yet to remit income earned by that date, to the UK. In such cases, the remittance basis rules may remain a consideration after 5 April 2025. However this is less likely to be a concern for those whose non-domicile status was ‘deemed’ by statute, because (as outlined below) the deemed domicile rules to 2024/25 only applied to those with relatively small sums of overseas income.

Remittance basis of taxation to 2024/25

The following represents a summary of the main considerations

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Paul Tew

Writer and advisor at Paywatch

Paul Tew is a freelance adviser, primarily in the areas of pay, personal taxation and remuneration planning. A frequent contributor to technical journals on pay and benefits issues, having written for the "In Business" section of the Times. Paul continues to supply articles for various recognised professional publications including Pay and Benefits magazine, Taxation magazine and Company's Secretary's Review. Paul also has had several loose leaf and bound books published on a variety of subject matter including PAYE, NIC, Sickness and Maternity Pay.Paul has written and presented training courses as well as headed up payroll and employment help desks and acted as an assessor for recognised Payroll/HR qualifications. Paul previously worked in the healthcare and oil sectors managing Pay and benefit services, so has many years of experience in dealing with PAYE and employment compliance issues across a broad range of industries and organisations.

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