One popular area in the ATX and BPT exams is the availability of the remittance election which can only be made by individuals who are non-UK domiciled that are UK resident. This means that if you are UK-domiciled, the remittance election is not available!
If the individual is not UK domiciled, the client can choose to be taxed on either the arising or remittance basis. The important aspect to remember is UK income and gains are always taxable for UK residents.
With regard to overseas income and gains, if you opt for the remittance election, then overseas income and gains are only taxable in the UK if actually remitted to the UK. So, by making the remittance election and keeping the income offshore, you can avoid a UK tax liability.
Unfortunately, this does have some adverse consequences.
The first is a remittance basis charge is added to the income tax liability for the tax year based on how long you have been UK resident.
If you have been UK resident for at least 7 out of the last 9 tax years, the remittance basis charge is £30,000.
Once you have been UK resident for at least 12 out of the last 14 tax years, this increases to £60,000 a year.
The second implication is you lose your personal allowance for income tax and your annual exemption for capital gains tax.
The final consequence is your overseas dividends remitted to the UK are taxed using the higher non-savings rate of tax instead of the lower dividend tax rates.
So, making the remittance election should be carefully considered and may not always be beneficial.
In the case of George Clooney who is US domiciled but UK resident, the remittance election is beneficial as he is very wealthy having received hundreds of millions from the sale of his tequila company, Casamigos to Diagio in 2017.
It is important to bear in mind that once George Clooney has been UK resident for 15 years, he will be treated as deemed UK domiciled and the remittance election will no longer be available to him.
On the other hand, his wife, Amal Clooney is UK-domiciled so the remittance basis is not available to her.
If you are planning on doing Advanced Tax in March 2023, I recommend you purchase Advanced Tax Condensed which will allow you to learn the technical rules at lightning speed.  
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