Background
11.Section 47 and Schedule 12 of Finance Act 2012 introduced a number of changes to the remittance basis of taxation provided by Chapter A1 of Part 14 of ITA 2007. These changes followed Government consultation in 2011.
12.In their formal response to that consultation in December 2011, the Government said further consideration would be given to a number of further issues with a view to possible legislation in Finance Act 2013. These included new rules for inadvertent remittances which can arise in certain circumstances which are set out in section 21 and changes to the rules on exempt property which are set out in this Schedule.
13.Property which is acquired using, or otherwise derives from, foreign income and gains and which is brought to the UK by or for the benefit of a relevant person (as defined in section 809M ITA 2007) will normally be treated as a remittance to the UK. However, certain property will not be treated as remitted to the UK where they meet the rules in sections 809X to 809Z6 of ITA 2007 and will instead be treated as exempt property.
