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HMRC internal manual

Capital Gains Manual

Remittance basis: disposals other than for full consideration: ITA07/S809T

A special rule applies when a foreign chargeable gain accrues to an individual on the disposal of an asset but he or she does not receive consideration equal to the asset’s market value. The amount of the foreign chargeable gain itself is not affected by this rule, but the asset on which the gain accrues is treated as deriving from the gain. This may be relevant when you consider whether any of the gain has been remitted, as the concept of something deriving from the gain features in many of the relevant conditions (see CG25341+)


An individual using the remittance basis sells a valuable foreign asset to a relevant person for less than its market value. The normal computational provisions in TCGA will usually apply to ensure that the amount of the gain reflects the market value. The relevant person brings the asset to the UK. The first condition A for there being a “basic remittance” is met (CG25341) but the second condition B would not be met because the property used in the UK is not the gain nor is it in the normal sense derived from the gain. But the special rule at ITA07/S809T means that we treat the asset as deriving from the gain and so condition B is met and there is a remittance of the full gain.