STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime At Spring Budget 2024 on 6 March 2024, the government announced that it will abolish the remittance basis of taxation and replace it with a residence-based regime, to commence on 6 April 2025. Individuals who opt into the regime will not pay UK tax on foreign income and gains for the first four years of tax residence. Overseas Workday Relief (OWR) will also be reformed with eligibility for the relief based on the new regime.
The government has also announced an intention to move to a residence-based regime for inheritance tax, with plans to publish a policy consultation on these changes, followed by draft legislation for a technical legislation, later in 2024.
For further information, see Spring Budget 2024—Private Client analysis — International and Spring Budget 2024 (web) (paras 2.38 and 5.29) and OOTLAR (para 2.3).
Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are either:
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non-distributor offshore funds, or (after 1st December 2009)
