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Home / Simons-Taxes /Personal and employment tax /Part E6 Overseas issues /Division E6.3 Domicile and the remittance basis /The remittance basis / E6.331A The remittance basis and practical implications—bank account structuring
Commentary

E6.331A The remittance basis and practical implications—bank account structuring

Personal and employment tax

In order to achieve the optimum tax position in the UK for an individual who is UK-resident and able to claim the remittance basis of taxation, it is very important to segregate funds so that it is clear which particular category of income or gain is being brought into the UK. This is because the remittance basis rules will determine the order in which the income and gains that make up the funds in a mixed account are treated as remitted to the UK (see E6.328).

Normally, separate accounts must be set up for each separate tax year from 2008/09 onwards and for each separate type of taxable or non-taxable income, gains, capital or other funds that are received in that tax year. However, HMRC accepts that where funds are credited to separate bank sub-accounts, the sub-accounts are separate and not mixed funds for remittance purposes1, also see the special relaxation of the rules for certain mixed earnings accounts at E4.1319.

Pre-entry account

Where a non-domiciled individual previously non-resident in the UK

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