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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Remittance Basis: Identifying Remittances: Condition D: Condition D - relevant debt

A taxable remittance may also occur when the property of the person identified under Condition D is used outside the UK, whether directly or indirectly, in respect of a relevant debt (ITA07/s809L(5)(c)).

A relevant debt is any debt that relates, directly or indirectly, to the money, property or service identified by Condition A RDRM33120 or Condition D RDRM33400, or the qualifying property or service identified by Condition C RDRM33200 as brought to, used, received or provided in the UK by or for the benefit of relevant person RDRM33030 (ITA07/s809L(7)).

The relevant debt provisions cover both the principle amount borrowed and the interest paid to service that debt and, where applicable, any debt created by the interest that is due on amounts borrowed (ITA2007/s809L(8)).