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UK abolition of remittance basis from April 2025: four-year FIG regime, TRF, OWR, protected settlements abolished, CGT rebasing, remittance definition changes

Practice notes
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Autumn Budget 2024

At the Autumn Budget on 30 October 2024, the Labour government confirmed it would scrap the remittance basis of taxation and bring in a residence-based regime, commencing on 6 April 2025. From the same date, inheritance tax (IHT) will also switch to a residence-based system, supplanting the previous rules tied to an individual’s domicile.

As part of the Autumn Budget package, the government published a set of documents, including:

  • a TIIN, ‘Reforming the taxation of non-UK domiciled individuals’;
  • a technical note outlining the income tax, capital gains tax (CGT) and IHT changes affecting UK-resident non-domiciliaries;
  • and 103 pages of Draft Finance Bill measures.
On 7 November 2024, Finance Bill 2025 (FB 2025) was published along with explanatory notes, including the draft legislation which was published at Autumn Budget. FB 2025 received Royal Assent on 20 March 2025 and is now enacted as Finance Act 2025 (FA 2025). The Finance Bill Tracking Service shows the amendments made to FB 2025 as it passed through its various legislative stages, and provides a comparison between those provisions and the draft measures first published on 30 October 2024. See also the Tax—Finance Bill 2025 tracker. This Practice Note focusses...

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Web page updated on 22/05/2026

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