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.
