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Where Taxpayers and Advisers Meet

Resetting of "Deemed Domiciled Clock"

JoePublic
Posts:6
Joined:Mon Jun 27, 2022 1:49 pm
Re: Resetting of "Deemed Domiciled Clock"

Postby JoePublic » Sat Jul 02, 2022 12:26 am

maths/Agoodman/darthblingbling - I have a follow up if you don't mind - Does un-remitted overseas income that arose during an earlier period of UK residence and where remittance basis was claimed, EVER (say after 6 years of continuous non-residence) become capital that can be remitted to the UK without tax consequences? Or do those amount have to be kept segregated and forever kept out of the UK.
Thanks again,

maths
Posts:8448
Joined:Wed Aug 06, 2008 3:25 pm

Re: Resetting of "Deemed Domiciled Clock"

Postby maths » Sat Jul 02, 2022 2:40 pm

There is no automatic conversion of taxable income into capital.

Once non-UK source income has arisen in a tax year in respect of which remittance basis is claimed (by the non-dom but resident individual) it in principle remains taxable as and when remitted. Thus, for example, remittance of the income in a later tax year when the individual is resident is taxable in that year of remittance (whether at that time the individual is domiciled or not).

However, a subsequent remittance of such income can be made "tax free" if remitted in a tax year of non-residence,

darthblingbling
Posts:516
Joined:Wed Aug 02, 2017 9:09 pm

Re: Resetting of "Deemed Domiciled Clock"

Postby darthblingbling » Sat Jul 02, 2022 5:15 pm

Think temp non res anti avoidance rules may kick in on unremitted foreign income while resident that is later 'remitted' while non resident. Probably not an issue if the taxpayer intends to spend 6 tax years as non resident however, but should be flagged.

JoePublic
Posts:6
Joined:Mon Jun 27, 2022 1:49 pm

Re: Resetting of "Deemed Domiciled Clock"

Postby JoePublic » Sat Jul 02, 2022 7:32 pm

Gentlemen - very helpful indeed. Thank you.


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