Tax treatment of double remittances has not changed

HMRC has replied to concerns cited by the Chartered Institute of Taxation about the potential for double remittances on foreign income or gains in the non-domicile changes in FA 2025. It suggested that in some cases where foreign income and gains (FIG) have been previously remitted but not taxed the legislation will treat a remittance as occurring on 6 April 2025 and thus trigger a tax charge on this date.

HMRC director Jon Sherman said: ‘Our long-standing interpretation of ITA 2007 s 809P(12) is that second and subsequent remittances are only relieved from tax if the first occasion of remittance has been charged to tax. The wording of s 809P(12) was amended in FA 2025 to clarify how this subsection operates; it has not changed how s 809P(12) functions.’

Referring to the financial secretary to the treasury’s explanation given during the passage of the...