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Commentary

E4.1315 Remittance basis earnings

Personal and employment tax

The remittance basis—overview

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 could only be accessed by foreign domiciliaries up to year 2024/25 (see E4.1312A for a summary of the 2025/26 domicile and remittance basis changes). 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.

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