With regard to the charge to tax under ITA 2007, s 727 at E1.1112, 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.
Finance Bill 2025, removes the exception for 'protected foreign-source income' from 6 April 20251. This reflects that from 6 April 2025 'protected foreign-source income' can no longer arise to a person abroad and that the income of the person abroad which is treated as arising to an individual will no longer be calculated by reference to their domicile status. Definitions of protected foreign source income are also deleted2.
Deemed domicile is relevant as explained in E1.1112 where the chargeable UK resident individual is either non-UK domiciled or has deemed UK domicile only by virtue of past residence
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