RDRM35010 - Remittance Basis: Amounts remitted: Quantification: Overview of Quantification
Source: gov.uk (2025-04-07)


Remittances of cash or property (#Remittances of cash or property)

Services and Consideration for services (#Services and Consideration for services)

Derived from (#Derived from)

Amounts remitted more than once (#Amounts remitted more than once)

Mixed Funds (#Mixed Funds)

This section of the guidance explains how, for the purposes of Conditions A and B, Condition C and Condition D (refer to RDRM33020 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33020)), the amount of foreign income or gains that is remitted to the UK and so chargeable to tax is calculated.

Remittances of cash or property

Sections 809P to 809S ITA 2007 provide some detailed instructions on how the amount of income or chargeable gains remitted to the United Kingdom is to be determined. In cases where, for example, a cash amount of foreign income or gains (see note below) is brought to the UK, this calculation is relatively straightforward, as the amount that is liable to tax is the amount of money that is brought to the UK. See RDRM35020 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm35020) for quantification examples.

Or, in the case of property brought to the UK that was purchased using foreign income and gains the taxable amount is not the value of the property when remitted, but the amount of foreign income and gains (see note below) that was originally used to fund the purchase.

From 6 April 2025, where money or property is used outside the UK to provide a benefit in the UK, the amount remitted is the amount of foreign income or gains that have been used to provide the benefit. It is not the value of the benefit in the UK.

Where property brought to the UK forms part of a set and only part of that set is in the UK the amount remitted is calculated by making a just and reasonable apportionment of the amount that would have been remitted if the whole set had been brought to, or received or used in the UK rather than just the part - section 809P(13).

Note: This chapter, and the examples below use the phrase remittance of ‘foreign chargeable gains’, or refer to such gains being ‘remitted’ or property or assets being ‘derived from’ such gains. This phraseology is used throughout as convenient shorthand. In practice foreign chargeable gains will usually be part of the proceeds from the sale of an asset, which will likely be a mixed fund, so the mixed fund rules may need to be considered too.

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Services and Consideration for services

When, rather than property being brought to the UK, foreign income or gains are used to provide a service in the UK or another benefit, the amount of the remittance is again the amount of the income or chargeable gains given in consideration for that service.

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Derived from

If the money or other property, service or consideration for the service mentioned in Condition A is not the original foreign income or gains but is derived from foreign income or gains of an individual, the amount remitted is equal to the original foreign income and gains from which the property etc derives. The scope of derivation can be very wide. Refer to RDRM33150 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33150) and to RDRM35030 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm35030)for quantification examples.

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Amounts remitted more than once

Where the same foreign income or gains are remitted more than once, section 809P(12) limits the amount remitted to the amount of the foreign income or gains, to prevent the same foreign income or gains being charged to tax more than once.

For example, if an individual had a taxable remittance of £100,000 of foreign income in 2023-24, then a subsequent taxable remittance of £50,000 of that same foreign income in 2024-25, without section 809P(12) that individual would have taxable remittances totalling £150,000 in relation to £100,000 of foreign income. Section 809P(12) therefore limits the total amount that can be charged to tax in relation to that foreign income to £100,000.

This means that section 809P(12) effectively reduces the amounts of subsequent remittances of the same foreign income or gains, but only reduces the amount of a subsequent remittance if an earlier remittance of the same foreign income or gains has been charged to tax.

To note, the wording of section 809P(12) was amended in FA 2025 to clarify how this subsection operates; it has not changed how section 809P(12) functions.

Example

On 3 April 2020 Gilbert transferred £350,000 of his foreign gains to his UK bank account in order to purchase a house in Oxford. The funds remained in his account until 1 May 2020, when they were used to complete the purchase.

Gilbert remitted the foreign gains during the 2019-20 tax year when he transferred them to his UK bank account. As Gilbert is UK resident, he was taxed on the remittance of £350,000 of foreign gains in 2019-20. In 2020-21, when Gilbert used his foreign gains to purchase a house, this was another remittance as it meets Conditions A and B. However, because Gilbert has previously remitted the same £350,000 of foreign gains, his remittance in 2020-21 is reduced by reference to the amount of foreign gains previously remitted and taxed in 2019-20. Therefore, the amount remitted in 2020-21 that is taxable is reduced by £350,000 to nil so there is no tax charge in 2020-21.

If Gilbert had not been charged to tax on the 3 April 2020 remittance, section 809P(12) would not have reduced the amount remitted on 1 May 2020, and he would have had a taxable remittance of the £350,000 of foreign gains in the 2020-21 tax year. However, if Gilbert had not been charged to tax because he was non-UK resident for the 2019-20 tax year, the foreign gains may qualify for re-remittance relief – see RDRM35090 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm35090).

Mixed Funds

Determining the amount of remittances from mixed funds is governed by strict statutory rules. Mixed funds are funds containing two or more types of income, gains or capital, or funds containing income, gains or capital from two or more tax years.

Although the principle of these rules is fairly simple to follow, their application requires detailed knowledge and accurate labelling of precise year and sources of income, gains and capital that make up the mixed fund, and details of all transfers where money leaves that mixed fund. You will need to obtain this information in order to check any amounts remitted from mixed funds.

Also refer to RDRM34000 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm34000) for exceptions such as art brought to the UK for public display, repair etc.