A significant change of policy by HMRC late yesterday. My colleague Geoff May describes Revenue and Customs Brief 16 (2015) as “an outbreak of common sense”- rare from the Revenue - with the possibility that further guidance may be issued soon after consultation with professionals.
It's good for arrangements in place before the withdrawal of the concession by HMRC on 4 Aug 2014, but even some cases not within the document's wording may be considered by HMRC. Specialist advice needed before taking action.
): - https://www.gov.uk/government/publications/revenue-and-customs-brief-16-2015-remittance-basis-treatment-of-foreign-income-and-gains-used-for-loan-collateral/revenue-and-customs-brief-16-2015-remittance-basis-treatment-of-foreign-income-and-gains-used-for-loan-collateral