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Posted Tue, 26 Mar 2024 14:48:01 GMT by Glorfindel Sindar
Hello, I am a non-dom who has previously claimed the remittance basis. I no longer claim the remittance basis and pay UK tax on my worldwide income. I understand that if I ever bring unremitted funds to the UK, I will have to pay tax on them. However, now that I am paying tax on my worldwide income, what rules apply to the income derived from investing the unremitted funds? For example, John sold a business in Australia while living in the UK as a non-dom. He paid tax on the gain in Australia and kept the funds there, amounting to £500,000. He did not remit any of this to the UK and declared this as unremitted on his self-assessment in the relevant tax year. John no longer claims the remittance basis and pays tax on his worldwide income. He invested the unremitted £500,000 in Australia and earns £55,000 a year in interest. The Australian government keeps 10% as withholding tax, and the remainder is paid into a clean bank account that only receives this interest payment. John then declares this interest on his self assessment, and pays top-up tax to the HMRC. Is John now able to bring the £50,000 (£55,000 minus Australian withholding tax) to the UK without additional charges? Noting that the principal unremitted sum of £500,000 remains unremitted.
Posted Thu, 28 Mar 2024 15:22:35 GMT by HMRC Admin 25
Hi Glorfindel Sindar,
Please refer to guidance here:
Paying tax on the remittance basis (Self Assessment helpsheet HS264)
Thank you. 
Posted Thu, 28 Mar 2024 15:41:31 GMT by Glorfindel Sindar
Thanks for your reply. However, the guidance you refer to is not helpful for the explicit example above, as it does not comment sufficiently on the switch from the remittance to the arising basis. I understand the consequences of bringing previously unremitted capital to the UK; what I need clarification on is the consequence of bringing the income from that invested capital to the UK in a year when the income is fully declared, and UK tax is paid on it. Please, can you comment further?
Posted Wed, 03 Apr 2024 14:51:12 GMT by HMRC Admin 5
Hi Glorfindel Sindar

HMRC cannot comment on specific examples and you will therefore need to contact us direct on 0300 200 3310 for specific advice.


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