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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 - income arising in the Republic of Ireland

RDRM31330 | Remittance Basis: Introduction to the Remittance Basis: Comparisons with pre-April 2008 regime: Other changes - income arising in the Republic of Ireland

From HM Revenue & Customs · Remittance Basis and Domicile Manual

For years before 2008-2009 individuals who were resident but not domiciled or not ordinarily resident in the UK were chargeable to tax on the arising basis in respect of any investment income arising in the Republic of Ireland. The same applied to any earnings from employment with an employer resident in the Republic of Ireland (RoI).

This meant that the remittance basis was not applied to the individual’s Irish source income even if the individual used the remittance basis for other foreign source income.

Individuals who have previously self-assessed, or been assessed for these earlier years on their RoI income on the Arising Basis will not generally be permitted to alter that assessment unless they are within the usual claim time limits.

For years from 2008-2009 the same rules apply to all relevant foreign income and chargeable overseas earnings, regardless of the source of the income or (for Not Ordinarily Resident (NOR) taxpayers only) the residence of the employer.

Note: The concept of NOR no longer exists since the introduction of the Statutory Residence Test (SRT) on 6 April 2013.

Also refer to RDRM31540 Transitional Provisions - Republic of Ireland

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