Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine possible planning opportunities to safeguard a remittance basis user’s existing clean capital reserves.
The concept of clean capital is fundamental to UK resident foreign domiciliaries who wish to maximise the benefits of the remittance basis. In brief the term ‘clean capital’ means funds that do not represent foreign income and gains that would be subject to a UK tax charge if remitted to the UK.
Generally a remittance basis user (RBU) will wish to fund all of their UK spending using clean capital because a remittance of foreign income or gains will give rise to a tax liability. There are various planning techniques available to generate and tax-efficiently invest that clean capital but in this article we will consider possible planning to safeguard an RBU’s existing clean capital reserves.
There are situations when an RBU can avoid...
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Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine possible planning opportunities to safeguard a remittance basis user’s existing clean capital reserves.
The concept of clean capital is fundamental to UK resident foreign domiciliaries who wish to maximise the benefits of the remittance basis. In brief the term ‘clean capital’ means funds that do not represent foreign income and gains that would be subject to a UK tax charge if remitted to the UK.
Generally a remittance basis user (RBU) will wish to fund all of their UK spending using clean capital because a remittance of foreign income or gains will give rise to a tax liability. There are various planning techniques available to generate and tax-efficiently invest that clean capital but in this article we will consider possible planning to safeguard an RBU’s existing clean capital reserves.
There are situations when an RBU can avoid...
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