Taxation: Domicil
The question
To ask the Chancellor of the Exchequer, whether repatriations by non-residents using the Temporary Repatriation Facility will be subject to the (a) general anti-abuse rule, (b) transfer of assets abroad rule and (c) transfer of income streams rule.
Answered by Dan Tomlinson
Non-UK residents cannot use the Temporary Repatriation Facility, it is only available to individuals that have both previously benefitted from the remittance basis and are tax resident in the UK in the year in which they make the election. Tax residence is determined by the Statutory Residence Test.
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