The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought to crack down on those enjoying what some have seen as an excessively benign tax regime

A UK resident but non-domiciled individual can, for example, choose to pay tax on his or her foreign source income and gains only when they are brought into or “remitted” to the UK. This is called ‘the remittance basis’ of taxation and can give a significant advantage as compared to the normal position where an individual’s worldwide income and gains are taxed as they arise.

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