Non-dom delays

I have a non-domiciled client who tends to spend one or two years as resident in the UK every seven or so years. He is subject to the remittance basis and his absences from the UK are sufficient that I do not have to worry about the temporary non-residents rules.

However during my client’s last stay in the UK he made a substantial capital gain overseas. Although most of the funds remained offshore there were some remittances to the UK on which tax was paid.

It appears from my reading of TCGA 1992 s 10A that my client should consider remitting the balance during one of his future absences and that will ensure that he will not be subject to UK tax on the funds at all.

However suppose he delays his remittance until a subsequent year...