Pre-entry planning for non-domiciliaries

Produced by Tolley in association with and Steph Carr of BDO LLP

Employment Tax

Guidance

Key points

The non-UK 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.

The remainder of this guidance note is written primarily with the previous rules, applying to 2024/25, in mind. However 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 will remain a consideration after 5 April 2025.

As regards the general position to 2024/25:

•
assets and funds earned prior to becoming UK tax resident are considered clean capital (see definition below under Segregation of bank accounts ― splitting funds from different sources) and cannot give rise to a tax charge in the UK even if remitted when an individual is UK tax resident and

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Nicole Caraglia

Tax Manager, BDO LLP , Employment Tax, Global Mobility

Nicole is a Tax Manager within BDO London's Global Employer Services tax team. She has specialised in expatriate tax for 10 years, working in a Big 4 and a much smaller professional services firm before joining BDO in 2021.She has worked with a variety of clients, ranging from individuals and start up companies to global corporations with large global mobility programmes.She has experience in assisting clients with their global mobility programmes as well as regular consulting around assignment planning, remote working arrangements, employment taxes, social security and expatriate payroll operation.Nicole has contributed to TolleyGuidance in Employment taxes.

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