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With regard to the charge to tax under ITA 2007, s 720 at E1.1103, protected foreign-source income is relevant for 2017/18 onwards, until 5 April 2025, as a consequence of the introduction of the deemed domicile rule at E6.323B. The position is changed by Finance Bill 2025, from 6 April 2025, which removes the exemption for protected foreign-source income¹ The rules on tainting and the definition of protected foreign-source income are similarly removed from 6 April 2025². The deemed domicile rule is relevant as explained in E1.1107 where the chargeable UK resident individual is either non-UK domiciled or has deemed UK domicile only by virtue of past residence in the UK, ie where Condition B (but not Condition A) of the deemed domicile rule is met. Where relevant it gives an individual some relief from this charge. For this purpose, income is protected foreign-source income if³:

1. Ìý

   (a)ÌýÌýÌýÌý the income would be relevant foreign income (see E1.602) if it were the individual's