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This guidance note explains the concept of double remittances, which is where foreign income and gains are not taxable in the UK when they are originally remitted to the UK and are then re-remitted at a later date. The guidance note discusses the situations in which this might arise and whether the later re-remittance is taxable.

The issue of double remittances has been highlighted by CIOT in its correspondence on the matter with HMRC. The relevant points from this exchange are discussed in the guidance note below, but for those wishing to read the source material the time line is:

1. •

   26 March 2025: CIOT briefing

2. •

   4 April 2025: HMRC response to the CIOT briefing

3. •

   23 April 2025: CIOT response to HMRC’s letter

An outline of the remittance basis can be found at the Remittance basis ― overview guidance note.

The commentary below builds on the meaning of remittance in ITA 2007, s 809L and it is assumed that readers are familiar with the When are income and gains remitted? guidance note.