Employment-related securities and the remittance basis

Produced by Tolley in association with

Employment Tax

Guidance

Abolition of non-UK domicile basis of taxation from 6 April 2025

The non-UK domicile basis of taxation is abolished from 6 April 2025. This will affect fundamentally claims for exemptions on non-remitted income. The separate Abolition of the remittance basis from 2025/26 guidance note sets out the new and transitional rules, applying from 2025/26 onwards.

The remainder of this guidance note is written primarily with the previous rules, applying to 2024/25, in mind. There is more than one reason why it may be necessary to refer back to these earlier rules, after 5 April 2025. One example might be where an event happens in 2025/26 or later which creates tax liability, but some or all of the income was actually earned in 2024/25 or earlier (see the example provided by HMRC in ERSM165236).

In addition, it is possible employees will have established a non-UK domicile by 5 April 2025, but have yet to remit income deemed to have been earned by that date, to the UK. In such cases the remittance basis

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Karen Speight

Freelance Lecturer

Qualified as both a solicitor and a Chartered Tax Advisor, Karen has over 25 years' experience in professional services, including 11 years as a partner at Ernst & Young. Whilst in practice, she specialised in all aspects of employee reward and development including design, implementation, compliance and administration, and now enjoys using that experience to help develop others.

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