Q&As

A UK resident non-domiciled (RND) made a loan to X prior to becoming UK-resident. The loan is unsecured and interest-free. What are the UK tax implications for the RND if X pays the outstanding loan amount into the RND’s UK bank account?

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Published on LexisPSL on 08/10/2019

The following Private Client Q&A provides comprehensive and up to date legal information covering:

  • A UK resident non-domiciled (RND) made a loan to X prior to becoming UK-resident. The loan is unsecured and interest-free. What are the UK tax implications for the RND if X pays the outstanding loan amount into the RND’s UK bank account?
  • Inheritance tax
  • Capital gains tax

The Q&A is based on the following assumptions:

  1. resident non-domiciled (RND) had never been tax resident in the UK prior to making the loan to X

  2. the loan was made out of non-UK situs property

  3. X is an individual and is not resident in the UK for tax purposes

  4. RND has claimed the rem

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