It does, of course, need to be borne in mind that where a non-UK domiciled individual is carrying on an FHL business in another EEA state(s) then the remittance basis may apply. There are three circumstances in which the remittance basis in ITA 2007, Pt. 14, Ch. A1 could apply to income or gains from an EEA FHL business:

(1)a short-term UK resident (less than seven out of the last nine preceding years of assessment) has unremitted income or gains and claims the remittance basis without payment of the remittance basis charge (RBC);

(2)a long-term UK resident has unremitted income or gains and claims the remittance basis and pays the RBC; or

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