The CIOT has published a paper outlining concerns around HMRC’s position on the treatment of re-remittances of foreign income or gains on or after 6 April 2025. Recent discussions revealed HMRC’s view that funds previously remitted to the UK are only ‘cleansed’ after having been taxably remitted – rather than considering past remittances as non-taxable.
ITA 2007 s 809P was designed to prevent multiple tax charges where the same foreign income or gains are remitted more than once. The CIOT notes that that section refers to the ‘amount remitted’ rather than an amount remitted being chargeable to tax.
This position appears to change with FA 2025 Sch 9 para 5 amending s 809P to add a qualification that previously remitted amounts had been charged to tax. In response to the CIOT’s question around how this change would apply where the original remittance was made before 6 April 2025 but...
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The CIOT has published a paper outlining concerns around HMRC’s position on the treatment of re-remittances of foreign income or gains on or after 6 April 2025. Recent discussions revealed HMRC’s view that funds previously remitted to the UK are only ‘cleansed’ after having been taxably remitted – rather than considering past remittances as non-taxable.
ITA 2007 s 809P was designed to prevent multiple tax charges where the same foreign income or gains are remitted more than once. The CIOT notes that that section refers to the ‘amount remitted’ rather than an amount remitted being chargeable to tax.
This position appears to change with FA 2025 Sch 9 para 5 amending s 809P to add a qualification that previously remitted amounts had been charged to tax. In response to the CIOT’s question around how this change would apply where the original remittance was made before 6 April 2025 but...
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