Income Tax (Earnings and Pensions) Act 2003 section 33

Earnings remitted to UK

Section 33 defines when overseas general earnings are treated as having been remitted to the United Kingdom, including anti-avoidance rules targeting loan arrangements used to avoid the remittance basis of taxation.

• General earnings are treated as remitted to the UK if they are paid, used, or enjoyed in the UK, or transmitted or brought to the UK in any manner or form
• Anti-avoidance rules apply where overseas earnings are used to repay a "UK-linked debt" — broadly, a loan connected to the UK either because it was taken out in the UK, or because the borrowed money was received in the UK
• Where overseas earnings are used abroad to repay a UK-linked debt, those earnings are treated as remitted to the UK at the time they are applied to the debt (or, if the borrowed money has not yet arrived in the UK, at the point it does arrive)
• These anti-avoidance provisions only apply to individuals who are ordinarily resident in the United Kingdom