HMRC internal manual

Residence, Domicile and Remittance Basis Manual

RDRM34080 - Remittance basis: exemptions: property ceasing to be exempt property

Property may be exempt property because it satisfies the conditions for meeting the public access rule, the personal use rule, the repair rule or the temporary importation rule or a combination of these.

Property that ceases to be exempt property while still in the UK, either because it:

  • ceases to meet any of the exemption rules or
  • it is sold or otherwise converted into money while in the UK

will be treated as having been remitted to the UK at the time the exemption ceases. ITA07/s809Y.

Property that ceases to be exempt property is to be treated as remitted to the UK (and so potentially taxable) at the time it ceases to be exempt property. However, from 6 April 2012 exempt property which is sold in the UK will continue to be treated as exempt for remittance basis purposes if all the conditions listed in ITA07/s809YA are met (refer to RDRM34240).