Press releases

Non-UK domiciled individuals must reconsider the remittance basis charge “tipping point”

Autumn Statement

3 December 2014

Patricia Mock, a tax director in the private client services practice at Deloitte comments:

“Non-domiciled individuals in the UK, affected by the increase in the “remittance basis charge”*, will need to reconsider the “tipping point” at which paying the charge becomes worthwhile.

“This tipping point depends on the level of unremitted overseas income and gains compared with the remittance basis charge. The higher charge may lead more taxpayers to elect for the arising basis of taxation, thus potentially accessing the increased personal and capital gains tax allowances available.”

“In future, the decision on whether to elect for the remittance basis may be further complicated by the planned consultation on making the election apply for an extended three-year period. Currently, taxpayers may elect for the remittance basis to apply (or not) annually. Non-domiciled individuals will therefore need to consider a three-year timeframe and decide whether the election should be made.

“It is also noteworthy that those taxpayers who have been UK resident for 17 of the preceding 20 tax years will now be both “deemed” UK domiciled for inheritance tax purposes and subject to the new £90,000 super-rate for long term UK residents. This 17th year is now an even more critical threshold for those non-domiciled individuals who have been resident in the UK for many years.”

Visit our dedicated Autumn Statement website


Notes to editors

*Individuals who are resident but not domiciled in the UK can elect whether they want to be taxed on their worldwide income and gains, or their UK income and gains together with their overseas income and gains remitted to the UK. However, if they opt for the latter basis they receive no personal allowance or capital gains tax annual exemption and there is a charge (the ‘remittance basis charge’) for this basis of taxation, currently £30,000 for those who have been here for more than 7 years, rising to £50,000 for those who have been here longer than 12 years. The 12 year charge has increased from £50,000 to £60,000 per annum for those that were resident in the UK in 12 of the preceding 14 tax years, and there will also be a new super-rate of £90,000 for those resident in the UK for 17 of the last 20 years. 

About Deloitte

In this press release references to Deloitte are references to Deloitte LLP, which is among the country's leading professional services firms.

Deloitte LLP is the United Kingdom member firm of Deloitte Touche Tohmatsu Limited (“DTTL”), a UK private company limited by guarantee, whose member firms are legally separate and independent entities. Please see for a detailed description of the legal structure of DTTL and its member firms.

The information contained in this press release is correct at the time of going to press.

Member of Deloitte Touche Tohmatsu Limited.

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