Non Dom- future remittance

[GL]

An individual is currently non dom, non res and non ord res has income accruing overseas at the moment. If they become res and ord res in the future and then remit some of that 'overseas income' to the UK, will that individual suffer tax on the remittance of the 'income' that they had earned in a period in which they had no UK tax connections. (They are currently in the UK < 20 days per year).

[Ian Wright]

You can only be taxed on remitting income which was earned offshore whilst you were UK resident. Any income earned before Uk residency is not income. What is more important is once they are resident then what they do remit to the UK has to be done carefully as you do not want HMRC saying it is income earned since residency! There is an order to what HMRC deem to be being brought into the UK and if accounts are mixed up with income, capital, gains etc this can be a very messy affair. The remittance basis charge needs to be thought about too! It is seriously advised that professional advice is sort, especially if there is lots of money offshore!

I would also be careful of the res ord res position as a few cases have been heard making ord res much earlier than clients expected. HMRC making you res immediately due to intention. Lots to read here!

Ian

[GL]

thanks Ian