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Newsflash – HMRC issues updated guidance with respect to the use of foreign income or gains to secure loans used in the UK

Non-UK domiciled remittance basis taxpayers need to be aware of revised guidance recently issued by HMRC. Effective 4 August 2014, HMRC will take the position that foreign income and gains contained within a non-UK account will be considered a taxable remittance as soon as they are pledged as collateral for a loan used in the UK. This represents a change to its previous position which was that a loan used in the UK, secured against assets representing foreign income or gains, would not give rise to a taxable remittance, provided that the loan was “commercial” and it was “serviced.”