Paras 39 to 40: loan charge relevant step: interaction with remittance basis
Schedule 11 F(No 2)A 2017
Where an individual is chargeable on foreign earnings under section 26 ITEPA 2003 or on chargeable overseas earnings under section 22 ITEPA 2003, it is necessary to consider how remittance basis applies to the loan charge.
If a relevant step is treated as being taken under the loan charge provisions, the income from that relevant step counts as employment income of the individual to the extent that the income on which the loan charge is based has already been remitted to the UK. Such remittances can be in the year in which the loan charge arises i.e. tax year 2018 to 2019 or any previous tax year.