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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Charge on beneficiary of a non-resident - administration

TCGA92/S87 applies if a beneficiary of a non-resident settlement receives a capital payment from the trustees of that settlement. It treats the beneficiary as receiving a proportion of the trustees’ gains, a process commonly called attributing the gains. Any gains attributable to the settlor under TCGA92/S86, CG38435, are not included in the trustees’ gains attributable to the beneficiaries under section 87.

Liability under section 87 is dealt with HMRC Charities, Savings and International, Bootle and other specialist compliance offices. Please do not enter into any correspondence on these cases without contacting HMRC Charities, Savings and International, Bootle . If technical advice is needed or litigation proceedings are possible refer to HMRC Capital Gains Technical.

The HMRC website asks people creating non-resident settlements to contact HMRC Trusts & Estates Non Resident Trusts direct. If details of a new settlement are received in another office please send them to:

HMRC Trusts & Estates
Non Resident Trusts
Ferrers House
PO Box 38
Castle Meadow Road
Nottingham
NG2 1BB