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Before April 2008, foreign income could only be taxed as a 'remittance' if it was brought into the UK as cash. Therefore a non UK domiciled taxpayer could buy a foreign asset with foreign income, and then bring that asset into the UK without it being a 'remittance' (see 'Assets remitted before 6 April 2008' below). The meaning of a remittance was examined in numerous tax cases and although the decisions in these cases were generally superseded by the post 5 April 2008 rules, some of the principles that emerged in the pre-2008 cases remain relevant (see E6.332A).

It is important to note that pre-April 2008 remittance basis income and gains remain taxable under general principles, regardless of when the remittance takes place (for example, capital gains of the tax year 2006/07 remitted on 1 July 2023 are assessable in 2023/24). This is subject to certain exceptions (see below).

For HMRC guidance on the old rules and the transitional provisions, see:

1. Ìý

   •ÌýÌýÌýÌý RDRM31200: Comparisons with pre-April 2008 Regime

2. Ìý

   •ÌýÌýÌýÌý RDRM31400: Transitional