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STOP PRESS: The remittance basis is to be abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in Finance Bill 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

This guidance note outlines how an international corporate structure can affect the tax position of UK resident individuals who are shareholders, as follows:

1. •

   gains made in the corporate structure may be taxable on the shareholders personally ― see the Gains attributable to participators in non-UK resident companies guidance note

2. •

   income arising in the corporate structure may be taxable on the shareholders under the transfer of assets abroad rules

3. •

   special rules apply to individuals holding shares in offshore funds

In addition, certain reliefs such as under the EMI or EIS schemes require that the group carries on business in the