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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

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HM Revenue & Customs
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Remittance Basis: Remittance Basis up to 6 April 2008: Form of Remittance: Overdrafts and Loans

Following the cases of Hall v Marians (19TC582) and CIR v Gordon (33TC226) legislation was introduced so that a person with foreign income assessable on the remittance basis is not able to avoid tax on that income by obtaining an overdraft which could be enjoyed in the United Kingdom but repaid abroad out of the income.

Refer to ICTA88/S65 (6)-(9) or ITTOIA05/s834.