Introduction

Individuals who are not domiciled or deemed domiciled in the UK can bring foreign income and capital gains into the UK for the purposes of investment in UK companies without triggering a remittance. This is known as ‘business investment relief’. For more on the remittance basis, see the Remittance basis ― overview guidance note.

To be a qualifying investment, the company must be a private limited company whose shares are not traded on a recognised stock exchange.

The investment must be made within 45 days of the date the funds are brought into the UK.

There are provisions under which the funds will become a chargeable remittance if there is a 'potentially chargeable event', such as the sale of the shares or if the company ceases to trade. If this event occurs, the taxpayer has a grace period (which varies depending on the type of event) to take the funds out of the UK or reinvest them in another qualifying investment to avoid a remittance.

These provisions apply where the funds are brought