United Kingdom: HMRC withdraws guidance on use of foreign income or gains as collateral for loans

Global Watch ()
The UK’s tax authority, HM Revenue and Customs (HMRC), has revoked key guidance in respect of the interaction of loans and the remittance basis of taxation effective August 4, 2014. Under the revoked guidance, an individual loan secured with foreign income or gains was not regarded as a remittance when the proceeds of the loan were brought to the UK. With the guidance withdrawn, HMRC will likely take the position that money brought to or used in the UK under a loan facility secured by foreign income or gains is a taxable remittance.