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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Remittance Basis: Amounts Remitted: Mixed Funds: Remittances from mixed funds containing UK or non-taxable income or gains

A mixed fund may include amounts that have already been taxed in the UK or are not taxable for some other reason. The ordering rules in s809Q apply to such amounts in the following way:

  • UK employment earnings are treated as having been remitted first (ITA07/s809Q(4) - paragraph ‘a’)
  • All other UK source income and gains are dealt with under category ‘i’ and can only be taken into account when all of the individual’s foreign income and gains for that tax year have been remitted to the UK.