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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Remittance Basis: Exemptions: Exempt property - temporary importation rule

Property of any description that derives from foreign income or foreign chargeable gains that is brought to the UK is exempt property if it meets the temporary importation rule (ITA07/s809Z4(1)).

The temporary importation rule applies to such property which is brought to, or received or used in the UK so that Condition A of ITA07/s809L applies (refer to RDRM33120 Condition A - money and property) but it is in the UK for fewer than 275 ‘countable days’. If this rule is met, the bringing in of the property is not treated as a taxable remittance.

A countable day is a day, or part of a day on which the property is in the UK in circumstances that, if it were not for the exempt property rules there would be a taxable remittance.

When calculating the period of time for which an item of property has been in the UK, all periods of time when the property is in the UK are taken into account. This means that a separate 275 day period of time is not available each time an asset (such as a work of art, a car, or a boat) is brought to the UK.