During 2011/12 a non-UK resident client transfers a sum from his UK bank account to his US bank account which is automatically converted to US dollars.
He then transfers those US dollars to his Colombian bank account which is automatically converted to Colombian Pesos.
He then loans those Pesos to a Colombian company of which he is a working director and part-shareholder. The Colombian company is trading in Colombia (a luxury hotel) and needs those funds for trading purposes.
A year later, during 2012/13, the Colombian company repays my client part of the loan by transferring Pesos to his UK bank account which are automatically converted to UK sterling.
I am aware that exchange gains for individuals arising from bank accounts are exempt from 6 April 2012, but am wondering if the gains arising in these circumstances are likewise exempt (because they involve repayment of a loan which muddies the waters slightly)? Would the answer be any different if he was UK resident (which he is wef 2013/14)?
Thanks for any help.
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Money Laundering ????
Sounds like classic money laundering-tax is the least of your worries.