Income Tax Act 2007 section 809E

Application of remittance basis without claim: other cases

Section 809E allows certain non-domiciled UK residents to be taxed on the remittance basis automatically — without needing to make a formal claim — provided they meet specific conditions, and applies only up to and including the 2024–25 tax year.

  • The remittance basis applies automatically to UK-resident, non-UK-domiciled individuals who have no UK income and gains (or only taxed investment income of £100 or less), provided no foreign income or gains are remitted to the UK in the year.
  • The individual must either have been UK resident in no more than 6 of the 9 preceding tax years, or be under 18 throughout the year; deemed domicile rules also apply when testing domicile status.
  • "Relevant income and gains" that must not be remitted include the individual's foreign income and gains for the year in question and for every other year in which the remittance basis applies to them.
  • The individual can opt out of automatic remittance basis treatment by giving notice in their self-assessment tax return; this provision ceases to be available from 2025–26 onwards.

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