RDRM36430 - Remittance Basis: Remittance Basis up to 6 April 2008: Employment Income: Income cannot become capital
The 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 鈥榮ums received鈥� 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鈥� Fund Life Assurance Society v Farmer, 5TC502).