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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Remittance Basis: Introduction to the Remittance Basis: Transitional Provisions: Relevant foreign income and offshore loans - Example 7

Maurice is a UK resident, non-domiciled remittance basis user who borrows £1,000,000 from an overseas bank to purchase a UK residential property.

The loan is drawn down before 12 March 2008 but the bank required Maurice to obtain two guarantees for repayment of the debt, of which only one is secured on the UK residential property.

Repayment of a debt secured on the property itself is regarded as falling within the provisions of FA08/para 90 regardless of what guarantees might also exist. Likewise, any repayments made under such a guarantee will also be covered by the paragraph. However, any repayments made under a guarantee which is not secured on the UK property will not be covered.