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Contents

Official guidance
Remittance Basis and Domicile Manual

RDRM31200 · Remittance Basis: Introduction to the Remittance Basis: Comparisons with pre-April 2008 regime

  • RDRM31210 · Key differences between the rules before and after 6 April 2008
  • RDRM31220 · Using the remittance basis - automatic versus claim
  • RDRM31230 · Changes to old regime - ceased source
  • RDRM31240 · Changes to old regime - alienation
  • RDRM31250 · Changes to old regime - cash only
  • RDRM31260 · Changes to old regime - claims mechanism
  • RDRM31270 · Changes to old regime - offshore loans
  • RDRM31280 · Changes to old regime - gifts and deemed disposals
  • RDRM31290 · Other key changes - mixed funds
  • RDRM31300 · Other key changes - extending the definition of remittance
  • RDRM31310 · Other key changes - extending existing anti avoidance measures
  • RDRM31320 · Other changes - higher rate tax charge on foreign dividends
  • RDRM31330 · Other changes - income arising in the Republic of Ireland
  • RDRM31340 · Other changes - capital gains foreign losses
  1. Remittance Basis: Introduction to the Remittance Basis: Comparisons with pre-April 2008 regime: Contents
  2. Remittance Basis: Introduction to the Remittance Basis: Comparisons with pre-April 2008 regime: Other changes - higher rate tax charge on foreign dividends

RDRM31320 | Remittance Basis: Introduction to the Remittance Basis: Comparisons with pre-April 2008 regime: Other changes - higher rate tax charge on foreign dividends

From HM Revenue & Customs · Remittance Basis and Domicile Manual

Historically, foreign dividend income remitted to the UK was charged at the basic rate or higher rate of tax dependent on the circumstances of the individual concerned, instead of the usual dividend rates.

However for the tax years 2005-06, 2006-07 and 2007-08, the tax law rewrite project for ITTOIA 2005 unintentionally changed the rate at which foreign dividend income remitted to the UK by a higher-rate paying individual who was taxed on the remittance basis. This meant that in these years foreign dividends were charged at the upper dividend rate of 32.5%, instead of the higher tax rate for those years, which was 40%.

The position has been corrected with effect from 6 April 2008. Foreign dividends remitted to the UK after that date by an individual who is chargeable to tax on the remittance basis are, where applicable, charged at the higher rates of tax.

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