Remittance basis and raising debt over jewellery for non doms
Here's an interesting scenario.
Non Doms can purchase certain personal assets abroad out of foreign income and bring the assets into the UK without this being a taxable remittance.
This is because exempt remittances includes Watches and Jewellery that are for the personal use of the non dom or their immediate family.
So in theory a non dom could buy expensive watches out of overseas income and give them to UK resident grandkids without their being a taxable remittance.
What if the non dom went one further and they bought expensive watches abroad, brought them into the UK for their/their immediate family's personal use and then raised debt over the watches. If that cash raised was spent in the UK would this be classed as a taxable remittance. On first glance the debt provisions in the finance bill wouldn't apply as these apply to non doms raising debt that is settled from overseas income or gains.
The exempt property rules will cease to apply if the watches are sold or cease to be used for personal use. There is no mention of a restriction if debt was raised over them though. The debt could then be repaid from overseas income in the future if the non dom became non UK resident.
It would be worthwhile if this (or a variationon this) is a possibility reviewing the legislation in detail.