The future of the remittance basis of taxation

The remittance basis principle of taxation is deep-rooted in the UK tax system. When income tax was first introduced in 1799 it only applied to foreign income to the extent that such income was received in the UK the principle being that the UK government only had the right to tax income generated in or brought to the UK. The philosophy of taxation has moved on substantially since William Pitt the Younger and today all UK residents are generally taxable by default on their worldwide income and capital gains as they arise but for non-UK domiciled individuals who do not meet condition A or condition B of ITA 2007 s 835BA (see Domicile below) the choice to be taxed on foreign income and gains only on remittance to the UK still remains.

Research paper

Arun Advani...