6 Autumn Budget | 30 October 2024 Changes to the taxation of non-UK domiciled individuals The remittance basis of taxation for non-UK domiciled individuals will be replaced from 6 April 2025 with a residence-based regime. Individuals who opt into the new regime will not pay UK tax on any foreign income and gains arising in their first four years of tax residence. The previous government’s proposal of a 50% reduction in foreign income subject to tax in the first year of the new regime will not go ahead. For CGT purposes, current and past users of the remittance basis will be able to rebase personally-held foreign assets to 5 April 2017 on a disposal where certain conditions are met. A new residence-based system for IHT will be introduced from 6 April 2025, aimed at ending the use of offshore trusts (excluded property trusts) to shelter assets from IHT. The temporary repatriation facility will be extended to three years, expanding the scope to offshore structures, and simplifying the mixed fund rules. Overseas workday relief will be retained and reformed, with the relief extended to a four-year period and the need to keep the income offshore removed. The amount claimed annually will be limited to the lower of £300,000 or 30% of the employee’s net employment income. Loan charge review An independent review of the loan charge will be commissioned by the government. Further details will be set out in due course.
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