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Common concepts

E6.160 Foreign income and gains regime—overview

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 the remittance basis (meaning UK tax was only paid on foreign income and gains to the extent that these are brought to the UK in the tax year) or the arising basis (meaning UK tax is payable on worldwide income and gains arising in the tax year). For details of the concepts of domicile and deemed domicile, see E6.300A. For commentary on the taxation of non-domiciliaries up to 5 April 2025, see E6.324A.

From 6 April 2025 onwards, the concept of domicile is abolished for tax purposes, and as a consequence the remittance basis of taxation also ends¹. 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