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HMRC internal manual

Offshore Funds Manual

Investors in non-reporting funds: charge to tax on disposal of an interest: remittance basis - Regulation 19

Offshore income gains: remittance basis

Where an individual is not domiciled in the United Kingdom and the remittance basis applies to the individual for a tax year (see booklet RDR1 available on the HMRC website at ) then the amount of any offshore income gain arising in that tax year is treated as relevant foreign income of the individual (Chapter 2 Part 8 ITTOIA).

In a case where the individual is the beneficiary of a non-resident settlement and an offshore income gain arises to the trustees of the settlement then different rules apply - see OFM15600.