Treatment of loans secured on foreign income or gains by remittance basis users

The attached note highlights a change in HMRC’s approach to the treatment of loans made to remittance basis users where assets of the borrower are held by the lender. The note is to assist taxpayers and their professional advisers in considering the technical and practical issues in each client’s specific context.

This note was first published in December 2021. It has been updated for HMRC’s comments, to add two supplementary questions and HMRC answers and to reference new examples added to HMRC’s Residence, Domicile and Remittance Basis Manual