RDRM33430 - Remittance Basis: Identifying Remittances: Condition D: Connected operation - definition
Source: gov.uk (2025-04-07)


A ‘connected operation’ means an operation which is effected:
- with reference to a qualifying disposition (see RDRM33420 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33420))
- with a view to enabling or facilitating a qualifying disposition
Broadly, this means that a connected operation occurs where a relevant person (see RDRM33030 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33030)), usually but not necessarily the former remittance basis user, agrees with someone else (who is not a relevant person), that instead of the relevant person dealing with his or her foreign income or gains in such a way as to result in a remittance under Conditions A and B (see RDRM33100 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33100)), the other person will use their own property to provide an advantage to the relevant person in the UK and, in return will themselves benefit from the former remittance basis user’s income or gains.

In detail, this means that for a connected operation to arise the relevant person must make a qualifying disposition (see RDRM33420 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33420)).

Also, the relevant person will arrange with another person (who is not a relevant person) that property of that other person (which is not itself qualifying property of a gift recipient - see RDRM33260 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33260)):
- will be brought to, received or used in, the UK, and the property or a benefit enjoyed by a relevant person
- is consideration for a service that is enjoyed in the UK by a relevant person
- is used outside the UK, directly or indirectly, to provide a benefit in the UK for a relevant person
- is used outside the UK, directly or indirecly, in respect of a relevant debt
To note, the enjoyment of a benefit as a result of qualifying property being brought to, received or used in the UK, and the enjoyment of a benefit as a result of qualifying property being used outside the UK, applies to remittances on or after 6 April 2025.

The property referred to above must not be qualifying property of a gift recipient as this will fall within Condition C. However, this restriction relates to the property not the individual, so the same person may be a gift recipient under Condition C (see RDRM33200 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33200)) and, in other transactions, ‘a person whose property is used’ under Condition D.

It is important to note the words ‘with reference to’ and ‘with a view to enabling or facilitating a qualifying disposition’. The nature of the link between the connected operation and the qualifying disposition, or even which comes first, is not specified. This means that an individual cannot avoid a charge to tax by setting up complex structures to disguise foreign income or gains, or to try and ’break the link’ between something enjoyed in the UK and that income or those gains.

Where a connected operation is present and the other terms of Condition D are met, there is a remittance of the individual’s original foreign income or gains and tax is charged accordingly.

For more on relevant debts refer to RDRM33040 (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm33040).