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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Remittance Basis: Identifying Remittances: Condition D: Qualifying disposition - full consideration given

A ‘qualifying disposition’ does not take place if full consideration is given for the property which is enjoyed in the UK by the relevant person (ITA07/S809O(5)).

This means that Condition D of S809L does not apply where a taxpayer sells property to another person for an amount that is expected in a ‘bargain at arm’s length’, that is broadly the open market value of the property. However Conditions A and B RDRM33100 may be in point instead.

‘Full consideration given’ can include cases where property other than cash money is given in return.