Different statutory rules apply to the calculation of income or gains dependent on whether or not the remittance basis applies.
The commentary below applies to persons subject to income tax and capital gains tax, ie individuals, trustees and personal representatives.
This article discusses how to determine the amount of the foreign income or gains taxable in the UK. For a discussion of the amount of the credit against UK tax, see E6.435 and E6.433B.
Arising basis
Under the arising basis, a person is taxed in the UK on foreign income and gains as they arise. This is the default basis of taxation for most UK residents, including trustees and personal representatives. See E1.101 (income tax) and C1.102 (capital gains tax). However, individuals who are UK resident but are not domiciled in the UK may be able to be taxed in the UK on the remittance basis (see 'Remittance basis' below).
The following rules apply where credit is allowed for foreign tax in respect of any income or gains
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:40