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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

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HM Revenue & Customs
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Remittance Basis: Introduction to the Remittance Basis: Comparisons with pre-April 2008 regime: Other key changes - mixed funds

Prior to Finance Act 2008 there were no statutory rules on the treatment of remittances from funds that contained various types of income, capital gains and capital.

This created problems in classifying for taxation purposes whether a remittance to the UK actually consisted of employment income, interest, chargeable gains or capital, for example.

Finance Act 2008 has introduced statutory ordering rules that determine how much of a transfer from a mixed fund is treated as the individual’s income or chargeable gains, and the manner in which these amounts are chargeable to tax - refer to RDRM35200 Mixed Funds.