Readers’ forum: Claiming remittance basis on dividends from abroad

My client is a non-domiciled UK resident. She came to the UK in mid-2015 and has been claiming remittance basis.

She is a 10% shareholder in three trading companies abroad and has credit shareholders’ loan account balances with these companies as have the various other shareholders. The companies are non-UK resident for tax purposes and there is no UK double tax treaty with her home country.

Dividends voted are credited to these loan accounts for all the shareholders at their request. All the companies have the cash to pay the dividends but the shareholders wish to have this arrangement. At various times funds are paid out against my client’s loan accounts for foreign expenses and monies are also transferred to her UK and non-UK bank accounts.

Do readers consider the shareholders’ loan accounts are mixed funds akin to bank accounts despite the three companies...