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Introduction

UK resident individuals who are non-UK domiciled under general law can, up to 2024/25, benefit from the remittance basis of taxation which allows for relief from UK tax for non-UK sources of income which are not brought in (or remitted) to the UK in any way.

Note that the non-UK domicile basis of taxation is abolished from 2025/26 onwards. Full details are set out in the Abolition of the remittance basis from 2025/26 guidance note. Most of the following guidance therefore relates to years up to 2024/25. The potential for planning via the use of dual contracts, already limited as explained below, is therefore greatly reduced from 2025/26 onwards. On a practical basis, the remittance basis rules are however likely to remain relevant after 5 April 2025, but only insofar as a non-UK domicile has overseas income arising up to 5 April 2025, which has not been remitted to the UK by that date.

Up to 5 April 2025, one way in which the remittance basis can be utilised for employees is through the use of dual