According to HMRC a remittance can be thought of as 'any money or other property which is, or derives from, your offshore income and gains which are brought directly or indirectly, into the UK for your benefit or for the benefit of any other relevant person'1.
The statutory definition of a remittance is broad and covers a whole host of situations in which a remittance may occur whenever non-UK income and gains are 'used' in the UK even if they are not physically brought to the UK. To determine whether a remittance has occurred, it is necessary to consider the conditions set out in ITA 2007, s 809L. This section introduces four condition clauses: Conditions A and B, which are taken together, and Conditions C and D which stand alone2 (see below). All four conditions use the term 'relevant person' (see E6.324D) which always includes the individual to whom the income or capital gains originally accrued but can also include family members, companies and trustees.
There are also ongoing exemptions with respect
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Web page updated on 17 Mar 2025 17:41