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.
Join our mailing list and receive the latest updates and news from Rooks Rider. Enter your email address below to sign-up.