HMRC have withdrawn the concessional treatment for commercial loan arrangements where unremitted foreign income or gain is used as collateral.

Money brought to or used in the UK under a loan facility secured by foreign income or gains will be treated from 4 August as a taxable remittance of the amount of foreign income or gains.

If the loan is serviced or repaid from different foreign income or gains, the repayments of capital and interest will constitute remittances in the normal way.

Revenue officials say the change was made after they saw large numbers of arrangements they did not consider to be …