For the latest New Development, see ND.2751.
An exemption is available to encourage UK resident foreign domiciliaries to invest in UK businesses using overseas income and gains, without being treated as having made a remittance. The exemption, referred to as 'business investment relief' (BIR), can be claimed where the qualifying investment occurs on or after 6 April 2012. See E6.333A.
The remittance basis income and/or gains underlying an investment that has received BIR are treated as remitted unless appropriate mitigation steps are taken within a set time limit (the 'grace period'), where there is a potentially chargeable event1. Potentially chargeable events and the appropriate mitigation steps are discussed below.
Potentially chargeable events
A potentially chargeable event for BIR occurs if2:
- Ìý
(a)ÌýÌýÌýÌý the target company ceases to be an eligible hybrid company, an eligible trading company, an eligible holding company or an eligible stakeholder company, or (see the definitions in E6.333A)3
- Ìý
(b)ÌýÌýÌýÌý the person who made the qualifying investment disposes of all or part of the holding4
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