Resident but non domicile case study scenarios

Spread the love

In this article, Ian Richardson gives some examples of the thorny issue of a UK resident individual who is also non-UK domiciled and what the tax consequences may be if he or she received income from various sources both in the UK and overseas.

For simplicity it is assumed that no withholding tax has been suffered in the country of origin. If tax had been paid at source one would need to investigate if there is a double taxation agreement and it is possible that relief to UK tax could be given for tax suffered abroad (but no refund would be received if there was more tax paid abroad on that income than is due in the UK).

Please note also that clean capital sums are not subject to the remittance basis since the definition of a remittance includes reference to sums originating from income or capital gains. Great care is required not to mix funds since with a mixed fund HMRC would assume income and gains are paid out first before the capital.

The client could however bring over capital sums if kept in a segregated account without triggering a charge to income tax. This would include amounts accumulated from income and gains prior to using the remittance basis.


Scenario 1 – Remittance basis not used

UK tax resident but Greek domiciled client who has no income offshore in the year of assessment – all his income and capital gains arise in the UK.

May as well just pay tax in the normal way i.e. as it arises.

Entitled to personal allowance and capital gains tax exemption limit


Scenario 2 – Remittance basis used but without claim

Same client as above but he has income in Greece of £10,000. He remits £9,000 of it to the UK leaving £1,000 as unremitted.

Since he has less than £2,000 in unremitted income and gains he can automatically use the remittance basis and pay UK tax only on the £9,000 (and of course his UK income and gains on an arising basis). The other £1,000 would only be subject to UK tax if he remits it to the UK.

Since he has not claimed the remittance basis he can keep his personal allowance and CGT annual exemption amount for the year in question.


Scenario 3 – Remittance basis claimed but not subject to a charge

Same client but this time he has £100k income in Greece of which he only remits £20k.

He must claim the remittance basis (or just pay tax on an arising basis which would mean he would pay UK tax on all his Greek earnings). This would be done by completing a self assessment return.

Since he has not been tax resident in the UK for 7 years out of the past 9 he would not have to pay for this privilege.

But he would lose his personal allowances and CGT exemption amount.

So if he was a 40% taxpayer he would pay £8k on this income but avoid having to pay UK tax on the other £80k income in Greece.


Scenario 4 – Remittance basis claimed and subject to a £30k charge

Same scenario as above but now he has been UK tax resident for 7 years of the preceding 9.

He would have to pay £30k for the privilege of using the remittance basis.

Now this bit is a bit more complicated! He can nominate foreign income to which this charge applies. So assuming he is a 40% taxpayer that would be £75k of foreign income (Grossed up amount of £30k tax at 40%). He has brought over only £20k already so he could then bring over the other £55k without charge in a later year.

He loses his entitlement to a personal allowance and CGT exemption by claiming the remittance basis.


Scenario 5 – Remittance basis claimed and subject to a £60k charge

Same scenario as above but now he has been UK tax resident for 12 years of the preceding 14.

He now would have to pay £60k for the privilege of using the remittance basis.

He can nominate foreign income to which this charge applies. So that would be £150k of foreign income (Grossed up amount of £60k tax and assuming he still only pays tax at 40%). He has brought over only £20k already so he could then bring over the other £130k without charge in a later year.

He loses his entitlement to a personal allowance and CGT exemption by claiming the remittance basis.


Scenario 6 – Super wealthy long stayer

Has offshore income and gains of £50m but he only remits £20m of them to the UK. He has been claiming the remittance basis for 12 years.

He would pay the £60k charge and so would avoid paying UK tax on the £30m not remitted to the UK.

He would pay UK tax on the £20m remitted to the UK but could nominate the income already deemed to be taxed by the £60k remittance basis charge.

Again, he loses his entitlement to a personal allowance and CGT exemption by claiming the remittance basis.


Note: HMRC state on their own website that this matter is very complicated and taxpayers should seek professional advice before using the remittance basis. The above represents our understanding of the situation as things stand but clients should always get professional advice.

Ian Richardson


What Clients Say About Us

  • Jacob LytheInvestment Management Assistant

    The guidance and assistance I received throughout the exam process was perfect for me. The small classes and the support I received every step of the way, was a crucial factor in helping me get over the line. Cris and Kathryn helped me whenever I had any struggles, whether that be a question query or an issue with an exam sitting. I would highly recommend Glascow Consulting to colleagues and others within the Financial Services industry.

  • Chenji MengWealth Manager

    I was in a CISI level 6 training Advanced Financial planning workshop hosted by Cris and over the two days of the intensive course feel much more confident ahead of my exam. He explained material very clearly in every section of the syllabus. I have moved qualifications from CII to CISI and Cris was able to explain exam techniques relevant to CISI that was of great help. Would highly recommend Cris.

  • Ben BolgerSenior Financial Planner

    Cris supported me through the CISI Level 7 Diploma in Advanced Financial Planning and the CISI Level 7 Diploma in Wealth Management. His knowledge of the syllabus and the financial services industry is fantastic and the way in which he taught the course material was always extremely engaging and practical. He was quick to respond to all my questions and clarify anything I didn’t quite understand, whilst providing extensive learning material to work through. My level of confidence approaching the exams after working with Cris was far superior to when I had approached exams preparing either alone or with other training providers. I would without doubt recommend to anyone wanting to pursue exams with the CISI to get in touch with Glascow consulting and start working with Cris

  • Dan RoddyTraining & Development Manager, Rowan Dartington

    Our firm has worked with Glascow Training for several years now, during which time we have called on Cris’s considerable expertise numerous times. Cris has coached CISI exam candidates at all levels and the results have been excellent. The feedback from colleagues who have sought assistance has always reflected his excellent knowledge of both the technical topics and of exam craft. As a training manager I particularly value Glascow Consulting’s responsiveness and flexibility in providing us solutions that fit our needs and Cris’s insight and advice is highly recommended.

  • Richard BeardRelationship Director

    The Pension Transfers revision course was highly informative and well structured including time to practice past questions. The mock exam provided was also very useful and very detailed answers. What has also impressed me is the speed and quality of response from Cris to technical questions which I have asked following my attendance on the course. I believe that Cris’s help was instrumental towards me achieving a pass particularly as I had no practical experience in the subject.

  • John RadcliffeRelationship Director

    Cris thanks for your help during and after the CISI Pension Transfers and Planning Advice course, I found the course and your support invaluable.  My understanding and approach to answering the questions was much improved giving me more confidence in approaching the exam.  It was good to be able to have a wider debate and discussion around the aspects of the syllabus for which I needed more clarification particularly when I don’t work in the industry.

  • Mark RobinsonDirector & Chartered Financial Planner

    I attended a 2 day workshop in London with Cris in preparation for the first sitting of the new CISI Level 6 Certificate in Advanced Financial Planning exam (March 2020). Having come from doing CII exams Cris was able to clearly explain how the CISI exams differ and guide me through the key parts of the syllabus. His style of teaching had the right balance of intensity and detail without overloading or confusing me and I left feeling in a much more confident and focused position. As a result I passed the exam with Merit and would have no hesitation in recommending Cris to anyone looking to improve their chances of passing.

  • Charlotte MetcalfeAssistant Investment Manager

    I was lucky enough to have Cris Glascow as my tutor for the Chartered Wealth Masters. I cannot recommend him enough, I really believe there is no other tutor like him.  His approachable and relaxed nature made the whole learning experience really enjoyable. The depth and breadth of his knowledge is truly incredible and unique. I believe this gave us the real X factor to pass. No question was too much trouble for Cris. His clear teaching style with multiple methods, wealth of experience and speed and efficiency in responding to queries really makes him stand out from the industry. Cris played a momentous part in helping me qualify and I am forever grateful to him.

  • Jonathan DilleyAssociate Investment Manager

    I had the pleasure of learning from Cris as I was studying towards my CISI Level 7 Diploma in Wealth Management. Whilst studying with Cris I was continually impressed by his depth of knowledge, his wealth of experience as well as his ability to teach and encourage everyone on his courses. He adapts his tuition and material to the groups strengths and weaknesses which I feel is crucial when undertaking such qualifications that require a depth of understanding beyond that which most candidates would possess when begging the qualification.

    I would give Cris and Glascow consulting my highest recommendation, I not only completed my qualification in a timely manner but also learned gleaned valuable skills from Cris that without his tutelage I certainly wouldn’t possess today.

  • Kevin Bray, FPFSFinancial Planning Director

    Having recruited two trainee advisers for the company I wanted to be sure they were given the best possible training for their level 4  qualification. The decision was taken to find the budget to bring in someone who could help them get through this first time. I had concerns that a centrally organised workshop may not be the answer from previous experience as larger groups are not always effective for every individuals learning style it also meant I could not dovetail the training with their work commitments. I needed something bespoke and I needed the right trainer with the right attitude. 

    I ascertained that Cris Glascow came with CISI approval so that satisfied my due diligence. I made contact with him and found him to have a flexible attitude and a professional approach. We agreed that he deliver bespoke training events for my trainees as part of their exam preparations. 

    I never had any doubt in the fact they would pass all elements required first time with the expert help of Cris. They are now level 4 qualified with an embedded knowledge of financial services which they could not have gained from just reading the workbook.

    I was sufficiently impressed with Cris that I subsequently asked him to train myself and a newly hired Senior Adviser colleague in the new CISI Pension Transfer & Planning Advice exam. This presented a fresh challenge as it was a new exam and he had to teach us in a subject neither of us had experience in ( DB Pension Transfers) With his help we both passed this exam at the first time of asking which just goes to show " you can teach old dogs new tricks!

    Cris Glascow is an excellent financial services trainer. He has had a 100% success rate with our team and I cannot recommend him highly enough.

  • Victoria YungPerformance Measurement

    Cris Glascow was my tutor when studying for the CISI Level 7, Chartered Wealth Manager qualification, which I achieved in 2014. Cris was a brilliant tutor, not only did he cover relevant topics but he explained them in a very clear and concise manner. One of the most valuable parts of the support were the mock exams provided. They were set at the appropriate level, they were marked quickly and relevant feedback was provided. To have a well prepared, approachable and knowledgeable tutor is so important when studying for the CISI exams especially at higher levels and as such I would strongly recommend Cris as a tutor to anyone studying for CISI qualifications. He is an excellent tutor.

  • Robert ClarkeInvestment Advisor

    I am very grateful to Cris for helping me with my studies for the Applied Wealth Management CISI exam. Cris is an expert in all areas of course material and I have no doubt in recommending him to anyone looking to pursue financial qualifications.

    Cris was also very approachable outside of teaching hours which showed his genuine passion for teaching.

  • Samuel TaylorAssistant Investment Manager

    Cris tutored me through the CISI Wealth Management program and under his guidance I passed all three modules on first attempt. His advice and tutoring were invaluable, and he made himself available to answer questions and help out at all times of day. His customised questions and detailed answers were particularly useful. Thanks Cris, I'm sure I couldn't have done it without you

  • Matt DickinsonInvestment Manager

    Cris stands out as someone that genuinely understands both the content of his training material and the individual needs of those taking the course. His training sessions are well paced and flow naturally between topics, with sufficient time reserved for open conversations and individual questions. Cris succeeds in creating an engaging learning environment which is supported by an impressive pass rate. I would happily recommend him to anyone and will certainly be working with him again.

  • Neil WinkworthSenior Manager 

    I was fortunate enough to have Cris deliver training to me for a number of CFP modules to me at a big 4 consultancy. Cris was fantastic from start to finish - most notably he knows his subject matter inside-out, delivers this knowledge and responds to questions in a logical and methodical manner - breaking complex concepts down into manageable chunks - and with a sense of humour. I highly recommend Cris to anyone considering training within his fields of expertise.

  • Katherine TaskerInvestment Manager

    I had the pleasure of being taught by Cris for my Chartered Wealth Manager Qualification. Cris is enthusiastic, incredibly knowledgeable on his subject matters and teaches in a way that is easily understood. He is incredibly supportive, not only whilst in the training session but also by responding to questions on the material in personal study time. I felt well prepared for each of the exams I sat having been taught by Cris. Cris’ achievement record speaks for itself and I would be happy to recommend him to anyone who is looking for an excellent trainer for financial services exams

  • Sebastian TaylorInvestment Adviser

    I was fortunate enough to be taught by Cris for the revision course for Portfolio Construction Theory and the Applied Management course. His level of knowledge was second to none and I found his teaching methods to be very clear and easy to understand. Any questions I had out of class were answered very thoroughly and timely, even late at night and also on the weekends. I have no doubt that my pass success was attributable to Cris. I would definitely recommend him to anyone looking to study towards a financial exam.

Latest Blog

Excellent results for our hardworking students

Excellent results for our hardworking students completing the September 2020 CISI narrative exams. Well done...

Read More

Covid-19 – Message to everyone

In a short space of time, we have adapted our services to replace our face...

Read More

CISI commissions Cris Glascow to produce updated course materials for Financial Markets exam

We are delighted to announce that the Chartered Institute for Securities and Investment (CISI) has...

Read More

View All


Subscribe to Qualifying matters, our regular email newsletter, for free tips and advice on getting the qualifications you need.

Registration Number: 5270482 VAT No: GB993 9795 28 All rights are reserved © Glascow Consulting