Beta This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Capital Gains Manual

Outstanding section 2(2) amounts


The outstanding section 2(2) amount as at the end of the year of transfer is calculated as follows:

  • Calculate the section 2(2) amount for the year of transfer.
  • Give effect to the application of TCGA92/S90 (transfers between settlements), CG38910+, to the year of transfer or any earlier year. This applies to transfers from and to the settlement.
  • Apply the ordinary matching rules in TCGA92/S87 to any capital payments made in the year of transfer or any earlier year to identify any unmatched amounts.
  • For the year of transfer only, add back any matched capital payment that is received by a non-UK resident beneficiary who will not be chargeable on the gain.