Market leading insight for tax experts
View online issue

Non-doms loan rules reversal

printer Mail

HMRC has dropped its transitional requirement for remittance basis taxpayers (i.e. non-domiciliaries) who used foreign income and gains as collateral for loans brought into or used in the UK before 4 August 2014 to take certain action before 5 April 2016 to prevent a remittance basis charge. The withdrawal of the concessional remittance basis treatment announced on 4 August 2014 will apply only to such loans brought into or used in the UK on or after that date.

James Badcock, partner and head of private client services at Collyer Bristow, welcomed the reversal in HMRC’s position for non-doms’ existing arrangements, saying: ‘Taxpayers have a legitimate expectation of consistency from HMRC and these types of changes make the UK less attractive to those considering moving here. While HMRC’s final interpretation of the rules in not unreasonable, the problem is inconsistency, which highlights the difficulty taxpayers have in understanding their position and chips away the UK’s position as a welcoming jurisdiction for high net worth individuals.’

See Revenue and Customs Brief 16/2015: Update on remittance basis treatment of loan collateral at