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The remittance basis—meaning of relevant debt
Published by a LexisNexis Private Client expert
Practice notesThe remittance basis—meaning of relevant debt
Published by a LexisNexis Private Client expert
Practice notesSTOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime
Finance act 2025 (FA 2025) which received Royal Assent on 20 March 2025, implements legislation to abolish the remittance basis of taxation and replace it with a residence-based regime, commencing on 6 April 2025. FA 2025 also replaces domicile as the key factor in establishing liability to inheritance tax. Other changes include amendment of the rules determining excluded property status, the abolition of protected settlements status of offshore trusts, and changes to overseas workday relief.
For information on these changes, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26. See also: Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.
This Practice Note deals with the provisions of section 809L of the Income Tax Act 2007 (ITA 2007) rules as they apply to debts and what constitutes a relevant debt under ITA 2007, s 809L(7) in particular.
An individual is treated as remitting foreign
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