Individual was previously a remittance basis user, but became taxable on the arising basis in 2017/18. In March 2017 he gifted some cash to his daughter who was 15 at the time. The cash came from his previously unremitted relevant foreign income. The transfer took place outside the UK and remains invested outside the UK in her portfolio.
Any income on the funds have been reported as his income and taxed in the UK. When she turns 18 we will report the income and capital gains on her personal tax return.
If she were to remit the money after her 18th birthday she is no longer a 'relevant person' in relation to her father, so my understanding is that the transfer to the UK will not be a taxable remittance (for either him or her). Do people agree? She would transfer the money for her own use in the UK and not return any money to father, or use it for his benefit. It was an outright gift to her in 2017. Could she make the transfer immediately after her 18th birthday or would it be better to wait until the next tax year?
I would be interested to hear people's thoughts or experience on this.