HMRC changes position on foreign income/gains used as collateral or loans by UK resident, non-UK domiciled Remittance based users (“non-domiciliaries”)

HMRC changed its position from 4 August 2014 on the taxation of non-domiciliaries using foreign income/gains as collateral for borrowings used in the UK. From that date using foreign income/gains in this way will result in a taxable remittance.

Non-domiciliaries who already have arrangements in place in reliance on HMRC’s previous concession will not be taxed on the foreign income/gains being used as security provided they take steps to either replace the security or repay the loan.

Read on to find out more. 

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