RDRM36430 - Remittance Basis: Remittance Basis up to 6 April 2008: Employment Income: Income cannot become capital
»Ê¹ÚÌåÓýapp investment of income abroad does not change its character as income and whether the investments or assets are realised abroad and the proceeds remitted here (Walsh v Randall (23TC55) and Patuck v Lloyd (26TC284)) or whether they are transferred here and then realised (Scottish Provident Institution v Farmer (6TC34)). Such transactions give rise to ‘sums receivedâ€� and the amounts are taxable.
On the other hand, the mere transfer to the United Kingdom of such investments or assets other than commercially recognisable forms of money is not a taxable remittance unless the asset is subsequently sold (Scottish Widows� Fund Life Assurance Society v Farmer, 5TC502).