HMRC 6 & RDR1: Residence, Domicile & Remittance Basis Archive Guide
Archival reference guide to HMRC 6 and booklet RDR1: tracing the history of UK remittance basis, deemed domicile, and transition to the 4-year FIG regime.
Short answer: HMRC 6 (introduced in 2008) and booklet RDR1 (introduced in 2013) were the foundational government guidebooks explaining UK tax residence, ordinary residence, domicile, and the remittance basis. With the abolition of the non-dom regime and introduction of the 4-year Foreign Income and Gains (FIG) rules from 6 April 2025, understanding these legacy frameworks is vital for managing historic contaminated bank accounts, mixed fund segregation, and Overseas Workday Relief. Matthew provides expert cross-border advice on international wealth and residence transitions.
Key points
- HMRC 6 was published in 2008 following the introduction of the £30,000 Remittance Basis Charge.
- Booklet RDR1 superseded HMRC 6 in 2013 alongside the enactment of the Statutory Residence Test (SRT).
- Abolition of Non-Dom Status: The remittance basis and domicile concepts were replaced from 6 April 2025 by the 4-year FIG regime.
- Mixed funds created under the HMRC 6 / RDR1 era require careful analysis to avoid punitive UK tax on clean capital transfers.
- Temporary Repatriation Facility (TRF) offers a preferential 12% to 15% rate on remitting historic offshore funds.
Evolution of UK non-dom guidance: from IR20 to HMRC 6 and RDR1
For decades, UK international taxation rested on common law principles outlined in Inland Revenue booklet IR20. In April 2008, following sweeping reforms that introduced the Remittance Basis Charge (£30,000 for non-doms resident for 7 of the last 9 years), HMRC released booklet HMRC 6 ('Residence, Domicile and the Remittance Basis').
In April 2013, the Statutory Residence Test was codified into law under Schedule 45 of the Finance Act 2013, abolishing 'ordinary residence' and replacing HMRC 6 with booklet RDR1. For twelve years, RDR1 served as the practical handbook for international individuals navigating foreign income, offshore trusts, and remittances.
Remittance basis mechanics and the mixed fund trap
Under the rules codified in HMRC 6 and RDR1, non-domiciled individuals were taxed on foreign income and gains only if those funds were 'remitted'—brought into, used, or enjoyed in the United Kingdom.
In theory, this allowed expats to keep overseas earnings tax-free. In practice, thousands fell into the dreaded 'mixed fund trap' under Section 809Q of the Income Tax Act 2007. When offshore accounts blended employment salary, foreign interest, capital gains, and pre-arrival clean funds, HMRC's statutory ordering rules deemed any transfer to the UK to be made from the most heavily taxed income first, triggering unexpected 45% income tax bills.
Transition to the 4-year FIG regime and Temporary Repatriation Facility
From 6 April 2025, the UK transitioned to a modern, residence-based 4-year Foreign Income and Gains (FIG) regime, ending more than two centuries of domicile-based tax planning.
Under the FIG rules, individuals who have been non-UK tax resident for at least 10 consecutive years can bring 100% of their qualifying foreign income and gains to the UK completely free of UK tax for their first four tax years of UK residence.
For individuals with pre-existing unremitted offshore funds from the HMRC 6 / RDR1 era, the Temporary Repatriation Facility (TRF) offers an unprecedented window to remit historic capital at reduced rates of 12% to 15%. Matthew analyses historic offshore account statements to unpick mixed funds and plan compliant capital transfers.
Navigate the 2025 FIG reforms with Matthew...
Matthew provides expert analysis of historic offshore bank accounts, designs clean capital segregation strategies, and prepares your annual SA109 filings under the new FIG regime.
Archival reference: historic HMRC 6 & RDR1 PDF downloads
For tax barristers, researchers, and trustees reviewing historic remittance calculations or offshore trust deeds created between 2008 and 2024, you can download the archival HMRC 6 reference copy below.
Please note: Domicile and the remittance basis were abolished on 6 April 2025. Modern UK tax exposure is governed by physical residence and the 4-year FIG framework.
Download historic booklet HMRC 6 (PDF)...
Need to review historic remittance rules or domicile definitions? You can download the 96-page reference PDF below. Matthew reviews your international bank accounts and structures clean capital repatriation under the new TRF rules.
Frequently asked questions
What was booklet HMRC 6 and why was it published?
HMRC 6 was published in 2008 as the comprehensive replacement for Inland Revenue booklet IR20. It detailed the controversial 2008 non-dom reforms, which introduced the £30,000 and £60,000 annual Remittance Basis Charges for long-term UK residents.
What happened to the Remittance Basis on 6 April 2025?
On 6 April 2025, the UK permanently abolished the remittance basis of taxation and the concept of domicile for tax purposes. It was replaced with a residence-based 4-year Foreign Income and Gains (FIG) regime for qualifying new arrivals, alongside a Temporary Repatriation Facility (TRF) for historic offshore funds.
What is the Temporary Repatriation Facility (TRF)?
The TRF is a transitional relief introduced in the Finance Act 2025 enabling individuals who were previously taxed on the remittance basis to remit historic untaxed foreign income and gains to the UK at a reduced tax rate (12% in 2025/26 and 2026/27, rising to 15% in 2027/28) without facing standard 45% income tax rates.
Why do I need to understand historic HMRC 6 and RDR1 rules today?
If you accumulated offshore funds, capital gains, or foreign trusts prior to 6 April 2025, the statutory mixed fund ordering rules (Section 809Q ITA 2007) still apply to those historic balances. Proper analysis prevents inadvertent remittances of taxable income ahead of clean capital.
Written and reviewed by Matthew S Manderson CTA ATT AMIT
Chartered Tax Adviser (CTA), Association of Taxation Technicians (ATT), Association of Malta International Taxation (AMIT). General guidance only; tax treatment depends on individual facts.