Gains from unremitted money for non-dom

[advisor31]

A UK resident, non-domiciled for tax purposes has shares in a foreign country.
These shares were bought with unremitted money, on which UK taxes had not been paid.
He holds this share with a broker, in accountA.

He receives dividends from these shares. He is paying taxes on the world arising basis that year (to avoid paying the remittance basis charge).
Can he repatriate this dividend to the UK without paying further tax?

In other words, if gains are generated with unremitted money, are these gains considered remitted once the taxes have been paid on them? Obviously, the capital would stay unremitted.

[maths]

Bit confused as you seem to mix gains with dividends?

If in a tax year remittance basis not claimed and in that year overseas shares are sold and dividend income arises overseas from those shares and UK CGT and UK income tax paid on gains and dividends respectively and all is credited to an overseas account then a mixed account subsists. Assume no foreign tax levied.

Any remittances of monies from that account are ordered per ITA 2007 s809Q(4).

In which case remittance first of divs and then gains.

However, if account also contains untaxed overseas gains and income then any remittance may constitute such gains/income not already taxed before getting at the already UK taxed stuff.

I have ignored possible cleansing.

[advisor31]

Maths, thanks a lot for your answer. It's still a bit complicated for me to understand. Let me clarify my question:

- I have account A and account B.

Account A contains shares bought with money that has not been taxed in the UK (unremitted income).
Account B is empty.
Say a dividend is made from these shares, and directly added to account B. UK tax is paid on these dividends. Am I righ tin saying that account B is clean, and these funds can be remitted to the UK without further taxes?

Thanks

[maths]

Yes you are correct.