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Rebasing of foreign assets held by former remittance basis claimants

Produced by a Tolley Personal Tax expert
Personal Tax
Guidance

Rebasing of foreign assets held by former remittance basis claimants

Produced by a Tolley Personal Tax expert
Personal Tax
Guidance
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Prior to 6 April 2025, UK resident individuals who were not domiciled or deemed domiciled in the UK had the choice to pay tax on:

  1. •

    the remittance basis ― broadly meaning that UK tax was only paid on foreign income and gains to the extent that these were brought to the UK in the tax year, or

  2. •

    the arising basis ― meaning UK tax was payable on worldwide income and gains arising in the tax year

From 6 April 2025, the remittance basis of taxation is repealed as a consequence of the abolition of the concept of domicile. This is replaced with a regime linked to the number of years of UK residency, which is colloquially referred to as the foreign income and gains regime (FIG regime). Although this is not a statutory term, it is used in this guidance note as a useful shorthand to reference the new regime. This regime is open to anyone who meets the residence conditions, including those who would have been considered

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  • 21 Mar 2025 08:38

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