Exemption for small remittances less than £1,000.
Included in the list of remittances for non doms is an exemption for small remittances. The legislation states that:
'Property of any description that derives from relevant foreign
income is exempt property if--
(a) the notional remitted amount is less than £1,000'
What is of interest though is whether this £1,000 refers to a total amount per tax year, or whether it is per remittance. If the latter it could represent a significant method of accessing overseas income.
Looking at the legislation there's nothing in there that addresses this. The only info provided is in relation to the "notional remitted amount",which is said to be the:
amount of income that would be taken to be remitted to the United
Kingdom in relation to the property.
There's nothing that covers whether its per year or not. I've asked the Revenue to clarify their interpretation on this, and will post details as soon as I know.
My view is that based on the wording of the legislation it's per asset and not tax year.
The context in which the £1,000 exemption is provided is in a list of other assets and if it was to be a yearly allowance you would expect this is to be mentioned in the legislation, rather than being silent on the matter which would indicate the same treatment for this as the other assets.