Business
investment relief (BIR) has been a feature
of the UK tax system since April 2012 and it is unusual, being the only
exception to the remittance basis of taxation that is ‘purpose-specific’. BIR allows UK resident non-doms to bring into
the UK untaxed foreign income and foreign gains without making a taxable
remittance of those funds. The purpose
of the relief is to encourage foreign investment into UK commercial
enterprise. However, as reliefs go, it
is relatively unloved. Its uptake since
inception has been limited but, thanks to the Autumn Statement 2015, it is back
in the spotlight again as the Government announced a consultation on altering BIR
to increase its use, with the aim of increasing investment into UK
businesses.
