HMRC have sought to address CIOT concerns about the potential for double remittances on foreign income or gains in the non-domicile changes in Finance Act 2025.
The CIOT argued that HMRC’s current view of past remittance rules appeared to be contrary to that of practitioners highlighting the potentially unforeseen tax implications for non-doms who make remittances on or after 6 April 2025 when they have made earlier remittances of the same foreign income or gains.
But HMRC director Jon Sherman in a response to the CIOT on 2 April 2025 said that nothing has changed in terms of HMRC’s view of the substantive legislation for the amount remitted: ‘Our long-standing interpretation of Section 809P(12) ITA 2007 is that second and subsequent remittances are only relieved from tax if the first occasion of remittance has been charged to tax ’ he said.
‘The wording of...
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HMRC have sought to address CIOT concerns about the potential for double remittances on foreign income or gains in the non-domicile changes in Finance Act 2025.
The CIOT argued that HMRC’s current view of past remittance rules appeared to be contrary to that of practitioners highlighting the potentially unforeseen tax implications for non-doms who make remittances on or after 6 April 2025 when they have made earlier remittances of the same foreign income or gains.
But HMRC director Jon Sherman in a response to the CIOT on 2 April 2025 said that nothing has changed in terms of HMRC’s view of the substantive legislation for the amount remitted: ‘Our long-standing interpretation of Section 809P(12) ITA 2007 is that second and subsequent remittances are only relieved from tax if the first occasion of remittance has been charged to tax ’ he said.
‘The wording of...
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