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For the latest New Development, see ND.2620.

Where a taxpayer remits any of their nominated income or gains to the UK whilst they still have 'unremitted remittance basis income and gains' (see E6.324G) then the nature of the taxpayer's remittances are re-characterised, both for the tax year in question and for any future tax year. Complex and draconian rules dictate the order in which income and gains are deemed to be remitted. These ordering rules apply irrespective of where the income and gains are situated, or when they are used¹.

The nominated income and gains have already suffered UK tax so no further tax is due if they are brought to the UK (see E6.324G).

HMRC's view is that the ordering rules start to apply from the tax year in which the nominated income or gains are first remitted and continue until all of the individual's foreign income or gains from that