The default basis of taxation for income tax and capital gains tax (CGT) for individuals is known as the 'arising basis'. Where the arising basis of taxation applies for a tax year, individuals are taxed on their worldwide taxable income deemed to arise and the chargeable gains deemed to accrue to them in the tax year.
All UK tax residents, whatever their domicile status, are subject to 'arising basis' tax on their UK source income and chargeable gains realised on the disposal (or deemed disposal) of UK situs assets. The 'remittance basis' is an alternative basis of UK taxation which can only be accessed by foreign domiciliaries. It can apply to foreign income and foreign chargeable gains of such individuals. Where it does apply, such funds are only taxable when remitted (brought) to the UK.
This article considers the basis of assessment for employment earnings for individuals working in the UK, outside of the UK or both.
A summary of the rules relating to the assessment of general earnings is provided in E4.106 and further detail is given
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Web page updated on 17 Mar 2025 16:53