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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

HM Revenue & Customs
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Remittance Basis: Identifying Remittances: Condition D: Connected operation - timing of remittance

The date of a remittance which occurs as a result of a connected operation RDRM33430 is deemed to be the date on which the property is first enjoyed by the relevant person and not the date on which the property was brought to the UK by the person with whom the ‘connected operation’ was agreed (ITA07/s809L(6)).

Any questions about the date on which the property is deemed to have been remitted to the UK should be referred to Specialist Personal Tax, PTI Advisory, Foreign Income and Remittance Basis Team.