E1.1121 Charge under ITA 2007, s 731 on transfer of assets abroad—application of remittance basis
The following rules apply where the individual on whom the charge falls is resident but not domiciled (and not deemed domiciled) in the UK. They apply where income is treated as arising to the individual under the TOAA rules at E1.1117 in a tax year for which the remittance basis applies to him (either by claim or automatically — see E6.324E, E6.324F)1.
To the extent that the income treated as arising is 'foreign deemed income, it is treated for remittance basis purposes as relevant foreign income (see E1.602) of the individual, with the consequences described in E1.6032. Income treated as arising to the individual is foreign deemed income if the relevant income to which it relates (see matching rules below) would be relevant foreign income were it the individual's own income3.
For the purposes of applying the remittance basis rules, relevant income, or a benefit, that relates (see matching rules below) to any part of the foreign deemed income is treated as deriving from that part of the foreign deemed income4.
Normally, if relevant foreign income is remitted to the UK in a split year (ie a tax year for part only of which an individual is UK resident), it is chargeable on the remittance basis only if remitted in the UK part of the year. This rule is disapplied