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HMRC internal manual

Capital Gains Manual

Foreign currency: debts in currency owing to non-domiciled persons - for periods up to 5 April 2012

TCGA92/S275 (c) & (l)

A debt is situated in the United Kingdom if the creditor is resident in the United Kingdom. However, a special rule applies where the debt is represented by a bank account in foreign currency held outside the United Kingdom by a resident but non-domiciled individual. TCGA92/S275 (l) places the situation of such a debt outside the United Kingdom. TCGA92/S12 (1) and TCGA92/S16 (4) then operate: gains arising on withdrawals are not chargeable unless remitted here; and losses may not be allowable.