Overview

Section 832 of the Income Tax (Trading and Other Income) Act 2005 imposes a tax charge where an individual is resident in a tax year and Relevant Foreign Income (RFI) is remitted to the UK.

In practice, this could produce a somewhat odd situation if an individual dies within the tax year - say, on 7 April - as it is technically possible for other family members (so-called ‘relevant persons’) to remit something to the UK later in the same tax year, thereby creating an inadvertent remittance by the person who has died.

Under the old rules, it was only remittances by the individual him or herself that were covered. The tax burden would, of course, be left to the executors to pay.

This briefing by Burges Salmon discusses the present situation in more detail following a clarification by the HMRC.

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