CIOT letter to HMRC regarding non-domiciled individuals, double remittances and 6 April 2025

The Chartered Institute of Taxation (CIOT) has written to HMRC in relation to the Finance Act 2025 and double remittances into the UK post-6 April 2025 and provided technical analysis concerning the construction of s.809P(12) as in force until 5 April 2025. This letter and attachment is in response to HMRC’s earlier letter dated 2 April in which they state it has been their ‘longstanding interpretation of s.809P(12)’ that second and subsequent remittances are only free from tax if they were charged to tax on the first occasion.