Readers’ forum: Remittance basis

My clients a married couple are returning from working overseas with their two minor children. The mother is UK domiciled but the father (and therefore each of the children) is domiciled in Cyprus.

The couple have made investments (contributing equally) on behalf of their children that give rise to annual income that is in excess of the limit in ITTOIA 2005 s 629 (£100 a child for each settlor) with the effect that it will be taxable on the settlor parents. The income is however less than £2 000 a child which would mean that the remittance basis would apply automatically if it were taxable on the non-domiciled children directly.

I suspect this is not the case but I do wonder if this gives the UK domiciled mother access to the remittance basis and the father automatic remittance basis access ...