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HMRC internal manual

International Manual

Clearance under the agreement: Calculation of one-off charge

The charge was calculated by applying an agreed formula. The formula identifieda value for Relevant Capital (Cr), which in most cases was the value of the assets in which a beneficial interest was held by an individual either at 31 December 2010 or at 31 December 2012.

The formula also considers the length of time that the assets had been held since 31 December 2002 and the rate of value increase over the same period, in order to determine the proportion of Cr that would constitute the charge. The minimum charge would be 21% of Cr and the maximum charge 41% of Cr.