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CIOT letter to HMRC regarding non-domiciled individuals, double remittances and 6 April 2025

The CIOT has written to HMRC in relation to the Finance Act 2025 and double remittances into the UK post-6 April 2025 and provided technical analysis concerning the construction of s 809P(12) as in force until 5 April 2025.

In the letter the CIOT states that it continues to disagree with HMRC’s technical analysis of the correct construction of s 809P(12) prior to 5 April and attaches a note giving further technical analysis on s 809P(12) for consideration. The CIOT is puzzled by HMRC’s statement that its interpretation is longstanding and highlights the wording of the explanatory note to clause 40 and schedule 9 of the Finance Bill in support of this.

However, on the assumption that HMRC’s interpretation is correct, the CIOT has asked for further clarification on why certain groups do not qualify for the relief in schedule 9 para 6.

See Simon’s Taxes E6.324DA.

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