Japanese remittance

Anna is UK resident and UK domiciled. She carries on a business in the UK as a sole trader; she is a freelance journalist working for a number of newspapers and magazines.

She has recently been offered a full-time position with a publishing company in Tokyo where she will live and work. However she hopes to continue to do some freelance work for her current clients.

Anna was advised that non-Japanese source income will only be subject to tax in Japan if it is paid or remitted to that country. She therefore proposes to retain her UK business bank account and ask her UK clients to make any payments into it. She will use that account only when she is in the UK on holiday or business – this is expected to be about two or three weeks a year.

Under ITTOIA 2005 s 6(2) non-UK...