Remittance Basis Ends April 2025: Your 90-Day Action Plan Before the Door Closes

The United Kingdom is undergoing one of the most significant tax regime transformations in recent memory. For decades, the remittance basis of taxation allowed non-domiciled (non-dom) UK residents to shield foreign income and gains from HMRC — provided they remained outside the UK or were not remitted to it.

That system will end on 6 April 2025. The window to prepare is closing rapidly, and the financial implications for affected taxpayers could run into tens of thousands — in some cases, millions.

If you are a non-dom or long-term resident with offshore income, this article provides your 90-day action plan to restructure, repatriate, and safeguard your assets before the remittance door shuts.

1. What Is the Remittance Basis and Why It’s Ending

Under the remittance basis, UK residents who are not domiciled here could opt to be taxed only on their UK income and gains — foreign income remained untaxed unless remitted to the UK.

While the rules helped attract global wealth and talent, they were often criticised for favouring the wealthy and enabling offshore income sheltering.

In the Spring Budget 2024, the Chancellor confirmed the regime’s abolition from 6 April 2025. It will be replaced by a new Foreign Income and Gains (FIG) regime, intended to simplify and align tax treatment between domiciled and formerly non-domiciled individuals.

In effect, this means:

• All UK residents, regardless of domicile, will become taxable on their worldwide income and gains.

• The remittance concept will disappear — any income or gains arising after April 2025 will be taxable in the UK.

• Transitional reliefs will apply for a limited period, but planning is required now to benefit.

2. Key Dates and Transition Timeline

3. Who Is Affected

The rule change impacts:

• Resident non-doms currently using the remittance basis;

• Returning expatriates who previously qualified for it;

• Trust structures designed under the old rules;

• Dual nationals and globally mobile professionals earning abroad;

• Foreign investors holding income-producing offshore assets.

If you have historically kept offshore earnings untaxed in the UK, these will soon become fully reportable and taxable.

4. The 90-Day Countdown: What You Must Do Now

Below is a structured 90-day plan to prepare for the end of the remittance basis — practical, chronological, and HMRC-compliant.

Days 1–30: Audit and Clarify Your Global Position

1. List all offshore accounts, investments, and income sources.
   Include bank deposits, portfolio investments, property rentals, dividends, and business interests.

2. Categorise them:

   • Clean capital (original funds brought to the UK tax-free).

   • Mixed funds (capital + income + gains).

   • Pure income/gains (taxable upon remittance).

3. Obtain full transaction histories — HMRC scrutiny post-April 2025 will be comprehensive.

4. Consult a UK tax professional to establish domicile and residence status under Statutory Residence Test (SRT) rules.

Days 31–60: Restructure and Repatriate Strategically

Once your offshore profile is mapped, begin restructuring with precision.

• Rebase foreign assets to 5 April 2019 values where permitted. This transitional rule may reduce the taxable element when gains are realised after 2025.

• Cleanse mixed funds. HMRC’s earlier “mixed fund cleansing window” (2017–19) is closed, but professional advisers can still identify and separate funds efficiently using transactional evidence.

• Bring in foreign income before April 2025.
  If you expect to need these funds in the UK, remit them now while they remain tax-free under the outgoing regime.

• Review offshore trusts.
  Trusts created under the old regime could face UK taxation on both income and capital distributions post-2025. Seek early restructuring or partial distributions.

Days 61–90: Formalise and Document

As the deadline approaches:

• Confirm tax residency plans. If you intend to leave the UK, do so before 6 April 2025 and meet statutory overseas tests to remain non-resident.

• Update bank and portfolio statements. Ensure clear records exist for all inbound remittances pre-deadline.

• Engage advisers for double-tax relief review. Many countries have treaties allowing credit for foreign taxes paid.

• Prepare for worldwide reporting. From 2025–26, include all foreign income/gains in your UK Self-Assessment return.

A qualified accountant specialising in international and personal taxation can handle this transition efficiently.
Firms such as My Tax Accountant assist non-dom clients in analysing exposure, repatriating wealth strategically, and ensuring compliance during the 2025 overhaul.

5. Transitional Reliefs: What Still Works in 2025–26

HMRC has proposed limited temporary reliefs to cushion the transition:

• 50% Foreign Income Reduction (2025–26 only):
  Eligible former non-doms will pay UK tax on just half their foreign income in the first year.

• Rebasing Relief (as of 5 April 2019):
  Allows certain non-doms to compute post-2025 gains using 2019 market values.

• Temporary Repatriation Facility:
  Provides a two-year window (to 5 April 2027) to remit previously unremitted funds at a reduced effective tax rate of 12%.

However, these reliefs require active claiming and precise eligibility. Failure to act in advance may disqualify you automatically.

6. The Implications of Inaction

Ignoring the upcoming change could prove disastrous:

• Foreign income and gains accumulated offshore will become taxable when arising — not only upon remittance.

• Unreported accounts may trigger HMRC enquiries or “nudge” letters.

• Double taxation risks arise if you pay tax abroad but fail to claim treaty reliefs properly.

• Trust income distributed post-2025 may lose its long-standing protection and become fully taxable to UK beneficiaries.

Ultimately, doing nothing could cost significantly more than undertaking structured preparation now.

7. Options for Those Planning to Leave the UK

Some long-term residents may find it tax-efficient to cease UK residency altogether before 6 April 2025. If that applies to you:

• Review the Statutory Residence Test to confirm non-residency.

• Avoid 183 days or more in the UK within any tax year.

• Cut “ties” such as UK accommodation, dependants, and employment contracts.

• Ensure departure is documented through flight records, visa status, and overseas tax registrations.

Leaving before April 2025 could preserve existing remittance benefits for earlier income years.

8. The Role of Trusts and Estate Planning

Trusts have long served as a primary planning vehicle for non-doms. With the regime change:

• Settlor-interested trusts will lose protection. Income and gains arising will be taxed on the settlor if UK-resident.

• Excluded property trusts created before 6 April 2025 may retain inheritance-tax (IHT) advantages — provided the settlor remains non-UK domiciled at creation.

• Post-2025 trusts will be fully transparent to HMRC.

Therefore, establishing or adjusting trusts before April 2025 is critical if inheritance or succession planning is part of your strategy.

9. Common Questions Non-Doms Are Asking

Will I still benefit from the 15-year rule?

No. The former rule allowing remittance basis use for up to 15 years of residence will be abolished.

What happens to income accrued before April 2025 but not remitted?

Under proposed temporary facilities, you may remit such income by April 2027 at a reduced 12% rate. After that, normal UK rates apply.

Will my offshore structures automatically lose protection?

Yes, unless restructured — HMRC will tax worldwide income from 2025–26 onwards.

Should I transfer money to the UK now?

If funds are “clean capital” or currently remittance-free, yes. Delay could trigger full taxation later.

10. The Value of Professional Guidance

Navigating the end of the remittance basis is complex — involving cross-border assets, double-tax treaties, and shifting HMRC guidance. A specialist can:

• Map your global income and gain exposure;

• Distinguish between clean and mixed funds;

• Structure early repatriations tax-efficiently;

• Prepare Self-Assessment adjustments under the new FIG rules;

• Liaise with offshore institutions for accurate documentation.

The right advice now can preserve wealth, ensure compliance, and prevent punitive HMRC action later.

11. Long-Term Outlook for International Taxpayers

The UK’s abolition of the remittance basis reflects a broader trend towards transparency and equality of tax treatment. Other jurisdictions, including Italy and Greece, have introduced fixed-sum or flat-tax alternatives to attract mobile high-net-worth individuals — but the UK has chosen integration over incentives.

Looking forward:

• Expect increased information sharing under the OECD’s Common Reporting Standard (CRS).

• HMRC will likely enhance enforcement via its Digital Assets and Offshore Compliance units.

• Domicile as a tax concept may itself evolve further in coming years.

In short, UK residency will now mean full fiscal transparency — worldwide.

12. Conclusion: Act Early, Document Thoroughly, Stay Compliant

The abolition of the remittance basis marks the end of an era for the UK’s globally mobile elite. With less than a year remaining, every week counts.

Your 90-day action plan is clear:

1. Audit and document all offshore holdings;

2. Restructure and remit before 6 April 2025;

3. Secure professional advice to claim transitional reliefs correctly.

Those who act now can mitigate exposure, manage remittances strategically, and preserve wealth legally. Those who delay may find that the door truly closes — and the cost of entry, come April 2025, is far higher than they imagined.