New Rules For Non Doms Living In The UK

Non-doms living in the UK are only taxed on their non-UK income to the extent that they bring it into the UK. The proposed change relates to a situation where a non-dom takes out a loan - in the UK or elsewhere - which they use in the UK, for example to buy a property. If that loan were repaid using foreign income or gains the law has always recognised that repayment as an indirect remittance & taxed it accordingly.

Less clear perhaps is a situation where the offshore income or gains are used as collateral for the loan. In most situations the collateral is just a safety net and the loan will be fully repaid using other means. HMRC previously took a view that this should be treated as a remittance only in obvious avoidance cases. The withdrawal of this treatment could mean that there is a remittance, even if the arrangement was always that the loan would be repaid using monies already in the UK.