This article should be read in conjunction with Part 1 – The end of non-domicile status 

The government recognises that some individuals will be adversely affected by the removal of the remittance basis. To provide a smoother transition, a number of temporary measures will be introduced:

Capital gains tax rebasing

Individuals who previously used the remittance basis will be allowed to rebase their foreign capital assets to a new value. This means that when they dispose of these assets, they will only pay capital gains tax (CGT) on gains accrued after the rebasing date. This applies to both current and former remittance basis users, offering a degree of protection against retrospective taxation on long-held assets.

Rebasing is available for current and past remittance users for disposals after 6 April 2025. To qualify, individuals cannot have been either UK domiciled or deemed domiciled at any time before tax year 2025/26 and they must have claimed the remittance basis in one of the tax years 2017/18 to 2024/25.

However, assets will be rebased to their market value at 5 April 2017 (rather than the original 2019 proposal) which was the date of rebasing that applied automatically to those becoming deemed domiciled for the first time on 6 April 2017. Those individuals will be able to continue to benefit from that rebasing provided they continue to meet the relevant conditions up to the end of 2024/25.

Assets held in trusts, which previously benefited from rebasing (to market value at 5 April 2008) will not qualify for any further rebasing. At present however, this rebasing only applies to gains matched to benefits paid to the settlor or other beneficiary.

From 6 April 2025, when many settlors will become taxable on gains as they arise, this 2008 rebased value can be used. This means effectively any trust set up in the last 16 years will not benefit from any rebasing and that for gains coming into charge on the settlor on an arising basis for the first time, there is no relief for any growth in value over the last 16 years.

Read the legislation relating to rebasing provisions

Remittance of pre-2025 foreign income and gains

Foreign income and gains that arose before 6 April 2025, while an individual was taxed under the remittance basis, will still be taxed only when remitted to the UK, maintaining continuity with the current rules.

Temporary Repatriation Facility

The Temporary Repatriation Facility will be available for a limited period of three tax years, from 2025/26. The Temporary Repatriation Facility rate will be 12% for the first two years and 15% in the final tax year of operation.