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I recently saw the following example in HMRC’s Residence Domicile and Remittance Basis Manual RDRM33140: ‘Tyler a remittance basis user donates an amount of money to a Battersea Dogs Home a UK charity by making a payment direct to the charity from his US bank account which contains his relevant foreign income. There has been a direct remittance of Tyler’s income into the UK; it does not matter that he or any other relevant person does not benefit personally from the money.’
I find the above example confusing in the context of a gift of funds from an offshore bank account by a remittance basis user to a cousin in the UK (who is not a relevant person for the purpose of the legislation in ITA 2007 s 809M).
The view expressed by way of the above example is not quite in line with...
