To determine whether a remittance has occurred for the purposes of the remittance basis of taxation, reference must be made to 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 alone (see E6.324C).
The occasions of remittance prescribed by Conditions A and B and Conditions C and D are expressed in terms of a 'relevant person'.
The use of the relevant person definition in determining occasions of remittance means that remittances can be triggered not only by the taxpayer but by any other relevant person. HMRC's view on this is that 'This broader definition aims to prevent individuals using family members or other close associates or entities, to make or receive remittances (as defined at Conditions A to D) of their foreign income or gains and then avoiding UK tax by claiming it is no longer “their” income or gains that has been remitted or that it is not them who have made or benefited from
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