E1.604 Repayment of UK-linked debts
The legislation described in this article does not apply from 2008/09 onwards following the introduction of new rules for the remittance basis of taxation, as to which see E6.324B, E6.324Conwards. In particular, seeE6.324H.
Before 2008/09, the anti-avoidance measures described in this article, based on those previously contained in TA 1988, s 65(6)–(9) applied to defeat the practice of taking out loans in the UK and subsequently arranging for the debt to be transferred abroad and repaid out of unremitted relevant foreign income.
For the purposes of relevant foreign income charged on the remittance basis (see E1.603), if a person who is was ordinarily resident in the UK used relevant foreign income outside the UK to satisfy a UK-linked debt, the person was treated as receiving the income in the UK at