Leading Professional Contributors
Dominic Lawrance, Charles Russell Speechlys

Collateral Damage: 'screeching handbrake turn' imposed by HMRC on taxable remittances for non-doms

Until 4 August 2014, the effect of HMRC guidance was that non-doms who were using the remittance basis could pledge foreign cash or investments, representing their unremitted foreign income and gains, as collateral for loans used for UK expenditure - without that being regarded as a taxable remittance. HMRC have just pulled a screeching handbrake turn in relation to this practice. They are now taking the position that such security arrangements do constitute a taxable remittance of the income and gains. This change of position will have serious implications for non-doms who have borrowed against the security of offshore cash or investments, and used the borrowed money in the UK.

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