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Most people in the UK are taxable on their worldwide income and capital gains on an arising basis. This means that income is taxable when it is paid to the individual or put at their disposal, for instance, by being credited to a bank account. Gains are usually taxable when the disposal occurs. If the individual is taxable on the arising basis, they must declare all their overseas income and gains in the tax year in which this arises, even if it is not remitted (brought) into the UK.

However, prior to 6 April 2025, UK resident non-domiciliaries were taxable only on their UK income and gains arising in the UK in the tax year. They pay UK tax on foreign income and gains arising in a tax year in which they were taxed on the remittance basis only if these are treated as remitted to the UK (whether in the same tax year or a later tax year). This is the remittance basis of taxation. The conditions as to who could access