Autumn Statement 2014 – Remittance Basis Charge for non UK Domiciled Individuals
Contributed by: Jan Lockley

If you are a non UK domiciled long-term UK resident Remittance Basis Taxation or RBC, allows you to pay income tax and capital gains tax on your overseas investment income and gains only if these income and gains are brought into the UK and then on an annual basis. The Chancellor had said that the government wouldn’t make any further changes to non-domicile taxation, including the RBC, for the 2010-2015 Parliament.

So, true to his word, the Chancellor announced on 3 December 2014 changes to the Remittance Basis Charge (RBC), payable by those who are resident but not domiciled in the UK, which will take effect in the next Parliament:

  • The RBC payable by those who have been resident in the UK for 12 out of the last 14 years will increase from £50,000 per tax year to £60,000 per tax year
  • A third level of RBC will be introduced for non-domiciliaries who have been resident in the UK for 17 out of the last 20 years, set at £90,000 per tax year (which mirrors the deemed domicile rules for inheritance tax)
  • There will be a consultation on whether the RBC should apply for a minimum of three tax years to prevent non-domiciliaries from arranging their affairs to pay the charge only occasionally

The RBC for those who have been resident in the UK for at least seven out of the last nine tax years will remain unchanged at £30,000 per tax year. According to the Statement, these changes will be introduced in Finance Bill 2015, however it is assumed that since the final bullet point will be subject to the consultation process, only the first two are likely to be legislated next year.

It is unclear whether these changes will be effective from the 2015/16 tax year or from the 2016/17 tax year.

Read more about non UK domiciled tax here.

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