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Representatives from CIOT recently attended a meeting with HMRC to discuss the issue of remittances of loan monies secured against collateral representing foreign income or gains. HMRC’s view is that if the full amount of such a loan is brought into the UK, the full value of the collateral is deemed to have been remitted and taxed accordingly. Anything less will be deemed as a remittance capped at the level of that amount actually remitted.
CIOT’s view is that the basis of an income tax charge should be capped at the level of monies actually remitted. Following this meeting, HMRC has agreed to review its position.
