HI all,
I am a Swedish and British citizen domiciled in Sweden, with residence in the UK. I am looking to invest in Sweden on remittance basis, and will be doing so through a Swedish 'shell account' similar to an ISA. My understanding from the below is that I am exempt from UK CGT so long as the assets remain outside the UK. If they are brought into the UK, the CGT relief is limited to what I have paid in tax in Sweden.
Is this correct?
Section 6.63 in the below "HMRC remittance basis guidance notes" states that "Investment income from a non UK source" only is liable to tax if it is remitted to the UK, "subject to the terms of any relevant Double Taxation Agreement".
https://www.gov.uk/government/publications/residence-domicile-and-remittance-basis-rules-uk-tax-liability/guidance-note-for-residence-domicile-and-the-remittance-basis-rdr1#cona
The below "UK/Sweden Double Taxation Agreement" states that:
"..income or capital gains are relieved from tax in a Contracting State and, under the laws in force in the other Contracting State, an individual, in respect of that income or that capital gain is subject to tax by reference to the amount thereof which is remitted to or received in that other Contracting State and not by reference to the full amount thereof, then the relief to be allowed under the Convention in the first-mentioned Contracting State shall apply only to so much of the income or capital gain as is taxed in that other Contracting State."
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/507416/UK-Sweden-DTC_-_in_force.pdf
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