What Is the 810/15 Nomination for UK Tax?
Learn how the 810/15 nomination allows non-doms to satisfy the UK's Remittance Basis Charge using foreign income without a further tax liability.
As of April 6, 2025, the United Kingdom’s remittance basis of taxation for non-domiciled individuals was abolished and replaced by a new Foreign Income and Gains (FIG) regime. Consequently, the Remittance Basis Charge (RBC) and the associated nomination process described in this article are no longer in effect. The following information explains how this system operated historically.
The UK’s tax system historically offered a treatment for individuals resident in the UK but domiciled elsewhere. This arrangement, the remittance basis, allowed them to be taxed on UK-source income and gains, but only on foreign income and gains brought into the UK. Long-term residents using this basis paid an annual fee known as the Remittance Basis Charge (RBC). Paying this charge involved a declaration to HM Revenue & Customs (HMRC) to designate the funds used for the payment.
The Purpose of the Nomination
The declaration to pay the RBC was made under Section 809H of the Income Tax Act 2007. Its purpose was to identify the foreign income or gains a non-domiciled individual was using to meet their RBC liability. This nomination was part of claiming the remittance basis for long-term residents, and a claim was invalid without it.
Bringing foreign income into the UK would ordinarily be a remittance, triggering a tax liability on those funds. The nomination procedure created an exemption, allowing a taxpayer to use nominated foreign funds to pay the RBC without that payment being classified as a taxable remittance. This allowed the charge to be settled using offshore funds without creating an additional tax bill. The nominated income or gains were then taxed to meet the RBC amount, while the rest of the individual’s unremitted foreign portfolio remained untaxed in the UK.
Information Needed to Make a Nomination
Before making a nomination, a taxpayer needed to determine the amount of the Remittance Basis Charge for the tax year, which depended on the length of UK residency. The charge was £30,000 for individuals resident in the UK for at least seven of the preceding nine tax years, £60,000 for those resident for at least twelve of the preceding fourteen years, and £90,000 for those resident for at least seventeen of the preceding twenty years.
The individual then had to identify sufficient unremitted foreign income or gains to cover the charge. For each source of nominated funds, the taxpayer needed to provide the amount, currency, the tax year in which it arose, and its country of origin to validate the nomination.
The Nomination Process
The nomination was made within an individual’s annual Self Assessment tax return on the ‘Residence, remittance basis, etc.’ supplementary pages, known as form SA109. The taxpayer would enter the total amount of nominated foreign income or foreign capital gains to cover the Remittance Basis Charge.
The taxpayer was also required to provide a breakdown in the tax return. This breakdown included the source country, the type of income or gain, the year it arose, and calculations showing how the tax on these nominated funds met the RBC amount. The deadline for making this nomination was January 31st following the end of the tax year. These nominated funds could be used to pay the charge, but if remitted to the UK for any other purpose, they would become subject to UK tax.