INTM602040 - Transfer of assets abroad: Non-domiciled individuals taxation up to 5 April 2025: The income charge - transition

The provisions described in INTM602020 have effect for the tax years 2008 - 2009 to 2024 - 2025. There are no specific transitional arrangements for the introduction of these provisions. As the income charge only looks at income arising to the person abroad in the tax year, it should not be necessary to have regard to income of earlier years in determining whether there is an amount that is to be regarded as foreign deemed income.

However, if there is foreign deemed income then, in considering any possible charge under Part 8 ITTOIA, it will be appropriate to consider all sums remitted to the UK in the tax year even if they arise, for example, from income of periods prior to the introduction of these provisions. Those remittances will fall to be tested against the rules in Chapter A1, Part 14 ITA 2007 as to whether they are taxable remittances.