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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

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Remittance Basis: Introduction to the Remittance Basis: Transitional Provisions: Republic of Ireland

Paragraph 83(3) Schedule 7 Finance Act 2008

Background

For years before 2008-09 individuals who were resident but not domiciled or not ordinarily resident in the UK were chargeable to tax on the arising basis in respect of any investment income arising in the Republic of Ireland.

This meant that the remittance basis was not applied to the individual’s Republic of Ireland source income, even if the individual claimed the remittance basis for other foreign source income.

Refer to RDRM31330 Other key changes - investment income arising in the Republic of Ireland.

The transitional rule applies to relevant foreign income that arose in the Republic of Ireland during tax year 2007-08 or any earlier year.

This ensures that relevant foreign income that arose in the Republic of Ireland and which was taxed on the arising basis for years to 2007-08 is not taxed again when remitted after that date.