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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Remittance from mixed fund and section 91 - gains only - example

A is a UK resident but non-domiciled beneficiary of a non-UK resident settlement and claims the remittance basis. A receives a capital payment of £1 million in 2014-15 which is matched against section 2(2) amounts of £500,000 for each of the years 2008-09 and 2014-15. Later in 2014-15 the beneficiary remits £500,000 and is chargeable on a foreign chargeable gain of £500,000. TCGA92/S91 will apply if the remittance is treated as coming from the part of the capital payment matched against the 2008-09 section 2(2) amount and not if it is treated as coming from the part of the capital payment matched against 2014-15 section 2(2) amount. ITA2007/S809Q(3) applies and the £500,000 remittance is treated as coming from the 2014-15 section 2(2) amount. Section 91 does not apply.