New queries, issue 4531

Arising remittance

Remittance basis rules for a non-domiciled taxpayer with a mixed account.

What are the remittance basis rules for a non-domiciled taxpayer who is taxed on his worldwide income on an arising basis since 2008 but who also has pre-2008 unremitted overseas bank interest in the same bank account?

A non-domiciled man has been resident in the UK for more than 17 out of the previous 20 years. He has an offshore bank account with mixed funds which comprises clean capital pre-2008 unremitted and untaxed foreign interest and post-2008 foreign interest taxed in the UK.

He has not previously made any remittances to the UK from this offshore account but now wishes to do so. No further capital has been added to this offshore bank account since 5 April 2008. If funds are remitted to the UK from this account will they be...