Residence & Domicile FAQ’s
HMRC have published a further selection of FAQs (and answers) in relation to Residence and Domicile issues. These FAQ’s address issues arising from the public and from taxation specialists.
The document includes answers to questions on:
– capital losses,
– remittances of nominated income,
– taxable remittances,
– discretionary trusts.
– guidance on sections 809L and 809W ITA in Schedule 7 FA 2008,
– offshore mortgages (including where a mortgage was used for some other purpose than acquiring an interest in a residential property). In the specific question part of a loan facility was used to release a second tranche of monies after a residential property had been purchased. This additional tranche of money was used to refurbish the property. HMRC confirmed in its answer that any relevant foreign income used to pay interest on this part of the debt will be treated as a taxable remittance in the UK.