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This commentary reflects the Finance Bill 2025 as published on 3 February 2025 and does not include changes reportedly being considered by Chancellor Rachel Reeves based on her comments at Davos.

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From 6 April 2025, the remittance basis of taxation is repealed as a consequence of the abolition of the concept of domicile.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