Matching in the same year - example
|Trustees section 2(2) amount||£50,000|
|Capital payments||beneficiary A||£30,000|
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.
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.