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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Matching in the same year - example

2013-14

Trustees section 2(2) amount     £50,000
       
Capital payments beneficiary A £30,000  
  beneficiary B £30,000 £60,000

A is UK resident. B is non-resident.

Each beneficiary is treated as receiving a relevant proportion of the 2013-14 section 2(2) amount.

£50,000 x £30,000 = £25,000
         
    £60,000    

Section 87 gains

A and B are both treated as accruing chargeable gains of £25,000 in 2013-14. Only A is chargeable to Capital Gains Tax on those gains. If A is non-domiciled they can claim the remittance basis on the gain, CG38805.

Each beneficiary has an unmatched capital payment of £5,000, £30,000 - £25,000. Assuming there are no unmatched section 2(2) amounts for earlier years these capital payments will be matched against section 2(2) amounts of a later year.

The trustees section 2(2) amount for 2013-14 is reduced to nil.