RDRM31240 - Remittance Basis: Introduction to the Remittance Basis: Comparisons with pre-April 2008 regime: Changes to old regime - alienation
For years before 2008-2009 it was possible to make a gift outside the UK of foreign income or gains to a third party, such as, for example to a close relative or non resident trust; this was sometimes referred to as 바카라 사이트˜offshore alienation바카라 사이트™.
Those foreign income and gains could then sometimes be brought to the UK in such a way that the individual to whom the income and gains originally belonged had the benefit, use or enjoyment of them in the UK, without attracting a UK tax charge.
Example
Before 5 April 2008 Shahina, who is resident but not domiciled in the UK settled £5,000,000, consisting of her foreign capital gains into a Jersey resident trust. The trustees of that trust then acquired a property in London for £2,000,000 in which Shahina lives rent free.
For years before 2008-2009 this would not be a taxable remittance to the UK by Shahina and would not therefore attract a charge to tax.
From 6 April 2008, where an individual바카라 사이트™s foreign income or gains are brought into the UK, or property is used or, services and benefits are provided in the UK by or for the benefit of individual and/or a relevant person there is a taxable remittance on the individual (subject to certain transitional provisions RDRM31400 covering the change to the new Chapter A1 rules).
The definition of 바카라 사이트˜relevant person바카라 사이트™ is wide but includes the individual, their spouse or civil partner, and their children and grandchildren under 18. Refer to RDRM33030: relevant person definition.