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I'd like to understand the tax treatment for a certain type of personal income under the current non-dom (remittance basis) rules. Specifically whether (1) personal income in the form of a dividend arising from a UK trading company owned by an EU holding (non-trading) company, in turn owned by the non-domiciled UK resident, is considered foreign or UK income; and whether (2) personal income in the form of a dividend arising from a foreign (EU) trading company owned by a UK holding (non-trading) company, in turn owned by the non-domiciled UK resident would be considered UK or foreign income. To clarify, these are two mirror situations and in each case the dividend is distributed from the holding company which owns a majority stake (50% or more) of the trading company. Consider the holding company as a personal private limited company (so the new QAHC provisions do not apply). Assume all dividends to be paid to a non-UK bank account (therefore non-remitted if they are non-UK income in the first place). Please assume the shareholding in the UK trading company in case (1) to predate the remittance basis election by the taxpayer, so BIR would not apply (and is outside the scope of the question). In case (1) I would assume the payment to be UK income because even if the dividend is distributed from an overseas company to an overseas account, the value produced by the company is UK-related and the company profited from the UK economy. In case (2) it would seem odd to treat it as UK income given that the holding company does not carry out a business and does therefore not generate any income per se. Finally, in general terms what is the normative and policy basis for defining UK income under the remittance basis? Finally, is there any difference if the shareholding in the trading company is qualified vs unqualified, and what is the relevant threshold? Thank you for your help.