Employment-related securities and the remittance basis

Produced by Tolley in association with

Employment 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.

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

The non-UK domicile basis of taxation is abolished from 6 April 2025. This will affect fundamentally claims for 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.

The remainder of this guidance note is written primarily with the previous rules, applying to 2024/25, in mind. It is possible employees will have established a non-UK domicile by 5 April 2025, but have yet to remit income deemed to have been earned by that date, to the UK. In

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Karen Speight

Freelance Lecturer

Qualified as both a solicitor and a Chartered Tax Advisor, Karen has over 25 years' experience in professional services, including 11 years as a partner at Ernst & Young. Whilst in practice, she specialised in all aspects of employee reward and development including design, implementation, compliance and administration, and now enjoys using that experience to help develop others.

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