International insights

The remittance basis was abolished from 6 April 2025. From that date, UK residents are generally taxed on the arising basis on their worldwide income and gains, unless they qualify for and claim relief under the new Foreign Income and Gains (FIG) regime.

The concept of a remittance remains relevant for individuals who have historic foreign income and gains from years before 6 April 2025, particularly where those amounts were previously protected under the remittance basis and are brought to, used in, or enjoyed in the UK after that date.

Transitional rules, including the Temporary Repatriation Facility, may affect the UK tax treatment of historic foreign income and gains. The detailed rules are complex, so advice should be taken before bringing funds or assets to the UK.

Common examples of remittances under the historic rules include:

1. Money transfers to the UK
   • Transfer or cash withdrawal from an offshore bank account to an account (yours or someone else’s) in the UK.
   • Giving funds to your spouse who then brings them into the UK.
     
2. Assets brought to the UK
   • Bought with foreign income or gains.
   • Sale proceeds from a disposal of overseas property sold at a gain (which, if the property was originally bought with unremitted income or gains, is a remittance of those too).
     
3. Services provided in the UK
   • Transfer from an overseas account to the overseas account of a trader who has provided you with a service in the UK.
   • Purchase overseas airfare to or from the UK.
     
4. Settling credit card bills, where
   • a foreign credit card is used in the UK.
   • a UK credit card is used abroad.
     
5. Offshore loans
   • Foreign mortgage repayments made for a UK property.
   • A foreign loan used to fund your life in the UK.
     
6. Gifts
   • To an overseas person who makes it available for your use in the UK.
   • To your adult child who lives abroad, who then gives the funds to your grandchild, who spends them in the UK.

   The above list is not exhaustive; there are many ways in which a remittance may occur. Where historic unremitted income or gains are involved, the position should be reviewed before funds are brought to the UK or used for UK purposes. 

When an individual comes to the UK, their tax residence status in the UK is decided by the UK’s Statutory Residence Test (SRT). See the full details in our Statutory Residence Test article.

However, many other countries have different rules as to what will make an individual tax resident. Being a tax resident in the UK does not mean you are not a tax resident in another jurisdiction. As a result, it is possible to be resident in the two (or more) countries at the same time. This is known as 'dual residence', and an individual may be subject to tax twice on the same income and gains.

To prevent this, double tax treaties have been signed with a number of countries to eliminate this issue and the residence will be decided under the terms of the treaty.

Tie-breaker rules, which are included in tax treaties, help determine which country has the right to tax an individual on particular sources of income or gains. Most treaties will decide where to tie-break based on the following:

• the country in which you have a home
• if there is a home in both countries (or neither), then consideration is given to where the 'centre of vital interests' is located – this is a subjective test and many factors would need to be considered in order to assess which country is the centre of vital interests
• if the centre of vital interests cannot be determined, then consideration is given to habitual residence, which is where the individual spends most of their time
• if the habitual residence cannot be determined, the individual’s nationality may be considered and, where necessary, the tax authorities may need to resolve the position by mutual agreement. 

Determining this will allow you to claim relief under the treaty so you are paying the right amount of tax.

We can work with your existing advisers or with our colleagues in the Crowe Global network to provide coordinated advice, balancing tax efficiency with your personal and business requirements.

Buying a property in the UK can seem a little daunting if you are a non-resident, as there are a number of complex tax issues you will need to consider.

Firstly, deciding the ownership of the property is important both to meet your objectives and to manage your tax exposure. Typically, residential property can be owned by either the following:

• a company
• a Trust
• or personally.

Determining how the property is going to be used is significant from a tax standpoint, as it could affect lots of different taxes and how much you may have to pay, including:

• Stamp Duty Land Tax (SDLT) — a 2% non-resident surcharge may apply to purchases of residential property in England and Northern Ireland, potentially alongside other SDLT surcharges. In some cases, the surcharge may be reclaimable if the purchaser subsequently meets the SDLT-specific UK residence conditions.
• Annual Tax on Enveloped Dwellings (ATED) - this only applies to properties owned by companies and can be a significant amount of tax if the property is not used for a relievable purpose such as commercial letting.
• Tax on rental profits — income tax for individuals and corporation tax for companies, with different rates and compliance requirements depending on the ownership structure.
• Allowable deductions from expenses such as loan interest – if the property is held personally, then there may be a restriction on the interest costs.
• Capital Gains Tax (CGT) – this applies to sales of UK property held by a non-resident.
• CGT reliefs such as Private Residence Relief (PRR) — if the property is your main home, then it may not be chargeable to CGT in full. However, where the property is in a territory in which you are not a tax resident, PRR may be restricted unless the relevant occupation conditions are met, including the 90-day occupation test for the relevant tax year.
• Inheritance Tax (IHT) — UK-situated property, including UK residential property, remains within the scope of UK IHT regardless of the owner’s residence status. From 6 April 2025, wider IHT exposure for non-UK assets is determined by residence-based rules rather than the previous domicile-based regime. Trust and corporate structures require careful review, and although debt may reduce the net value subject to IHT, the rules are complex, and anti-avoidance provisions may apply.

How you decide to own your property depends on your individual circumstances, so it is important to seek professional advice.

At Crowe we understand that plans can and do change and the costs of getting it wrong can be significant. We can work with your existing advisers or with our colleagues in the Crowe Global network to provide coordinated advice, balancing tax efficiency with your personal and business requirements.

View our checklist of things to think about before your move

If you are thinking about moving to the UK, it is important that you seek advice early to allow time for planning, not only in advance of your arrival in the UK but also your departure from your current home country.  

We have put together a checklist of some of the key questions you need to think about before making your move

• Do you understand the tax implications of coming to the UK?
• When do you expect to arrive in the UK? The timing of the commencement of your UK residence by reference to the UK’s Statutory Residence Test and cessation of residence in the country you are leaving are crucial in determining your tax liabilities.
• Have you been a non-UK resident for the previous 10 tax years, and could you qualify for the new four-year foreign income and gains (FIG) regime from the date you become a UK resident?
• Do you have historic foreign income or gains from before 6 April 2025, and should you consider the Temporary Repatriation Facility before bringing funds to the UK?
• What pre-arrival planning opportunities are available to you?
• How best to structure your investments and business interests for international tax efficiency?
• Are you intending to buy residential property in the UK? If so, you will need to decide the most appropriate structure in which to acquire the property.
• If you receive income or capital gains outside the UK, do you understand the application of the relevant tax treaties and how to claim relief from double taxation?
• Will you be exposed to UK Inheritance Tax? From 6 April 2025, the UK’s wider IHT rules are based on long-term UK residence rather than domicile, so pre-arrival and trust planning should be reviewed carefully.
• What are the deadlines to register with the UK tax authorities, file UK tax returns and pay any taxes due?

We can work with your existing advisors or with our colleagues in the Crowe Global network to provide coordinated advice, balancing tax efficiency with your personal and business requirements.