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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.11 Transfer of assets abroad /Transfer of assets abroad—charge on individuals receiving a benefit / E1.1121 Charge under ITA 2007, s 731 on transfer of assets abroad—application to qualifying new residents and remittance basis users
Commentary

E1.1121 Charge under ITA 2007, s 731 on transfer of assets abroad—application to qualifying new residents and remittance basis users

Personal and employment tax

Non-transferors receiving a benefit as a result of relevant transactions (see E1.1118), are assessable on any deemed income1.

Finance Bill 2025 brings in the concept of 'qualifying new resident' and brings an end to the remittance basis. Until 5 April 2025, the deemed income rule applies to UK resident remittance basis users. From 6 April 2025, the deemed income rule applies to qualifying new residents.

Qualifying new residents and foreign deemed income

From 6 April 2025 deemed income is 'foreign' if ,and to the extent that, the relevant income to which it relates would be relevant foreign income if it were the individual's. The deemed income is that for which the individual is entitled to claim relief under a foreign earnings election as a qualifying new resident2. See Matching E1.118

Remittance-basis users and foreign deemed income

The following rules apply, until 5 April 2025, where the individual on whom the charge falls is resident but

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Web page updated on 17 Mar 2025 16:08