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‘Amendment 24’: a tale of repeat remittances and dodgy drafting

Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) explain why advisers might not need to worry about defective drafting on remittances in the Finance Act.

Just over a year ago on 6 March 2024 UK resident foreign domiciliaries and their advisers were shocked by the announcement in the former Conservative Government’s final Budget of the impending demise of the remittance basis. It was disappointing but not altogether unexpected that Labour uncritically adopted the policy on coming to power.

What was unexpected and frankly bizarre was the Labour Government’s decision to change the terms of the remittance basis in the same legislation that would end the regime. The draft Finance Bill published in November 2024 included modifications to the definition of remittance some of which significantly extended the circumstances in which a taxable remittance would occur.

Cleansing of FIGs...

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