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Posted Fri, 01 Dec 2023 02:52:47 GMT by Nick Hill
I am a UK national but have not lived in the UK, or been a UK tax resident, for over 30 years. I own a non-UK company, that has never been or ever will be resident in the UK: RMGL. RMGL owns an apartment outside the UK. At the time of the purchase, I advanced funds to RMGL, to fund the acquisition of the apartment. The value of the apartment has increased and is now greater than the money I advanced to RMGL. I am considering arranging for the sale of the apartment owned by RMGL before returning to the UK and becoming a UK tax resident. I understand this will render me liable to UK tax on my worldwide income, including on remuneration or dividends from RMGL. However, my understanding is that the repayment of the loan due to me by RMGL will not be taxable in the UK, even after I am resident in the UK. Is this correct?
Posted Tue, 05 Dec 2023 09:08:46 GMT by HMRC Admin 8
The repayment of the loan would not be taxable in the UK.  
When you return to the UK, you will have to declare your world-wide income in a self assessment tax return every year.  
Where overseas tax is paid on this income, you can claim a foreign tax credit, to avoid double taxation.
Thank you.

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