RDRM32330 | Remittance basis: accessing the remittance basis: remittance basis charge - nomination of foreign income and gains: relevant tax increase

From 6 April 2025 it is not possible to use the remittance basis of taxation, however, any foreign income or gains that have arisen to a former remittance basis user prior to this date will continue to be taxed at the usual tax rates if they are remitted to the UK on or after 6 April 2025, subject to any amounts designated under the temporary repatriation facility (TRF) – see RDRM71000.

The guidance in this section only applies to tax years up to and including the 2024-25 tax year and remains for reference purposes only.

The Remittance Basis Charge (RBC) is either income tax or capital gains tax, or a combination of the two. It is tax due on nominated foreign income and/or nominated foreign gains respectively.

This is achieved through a calculation of the “relevant tax increase”, which is actually the difference between two tax calculations;

In brief, the first calculation is of the total tax actually payable by the individual in the tax year, including such tax as results from the nomination. The second calculation, yielding a lower amount, is the total of the tax payable by the individual in the tax year less tax charged on nominated foreign and nominated gains see examples at RDRM32340 onwards.

The Remittance Basis Charge cannot exceed £30,000 for those individuals who have been UK resident in at least 7 out of 9 tax years. £60,000 (previously £50,000 up to 2014-2015) for those individuals who have been UK resident in at least 12 out of 14 tax years. £90,000 for those individuals who have been UK resident in at least 17 out of 20 tax years (this amount is only applicable for 2015-2016 and 2016-2017, it was made obsolete with the introduction of deemed domicile from 6 April 2017).

Any nominations which produce an excessive relevant tax increase invalidate the claim under section 809B to be taxed on the remittance basis.