Historically non-UK domiciled individuals have been able to avoid paying UK tax on their foreign income and gains where those monies are not remitted to the UK. A remittance to the UK included bringing money to the UK to invest in a UK company.
It was felt that this discouraged investment in the UK and for this reason a special type of relief – ‘Business Investment Relief’ was introduced in April 2012 to encourage investment in the UK by not taxing qualifying remittances. Some of the conditions are perhaps unnecessarily restrictive. In many instances, for example, an investment in a UK company will qualify for relief but an investment in a UK partnership will not.
The government will consult on how to change the rules on Business Investment Relief to encourage greater use of the relief and increase investment in UK business by non-UK domiciled individuals.