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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Remittance Basis: Remittance Basis up to 6 April 2008: Occasions when there may not be a remittance: Gifts and deemed disposals

An individual who was not domiciled in the UK was able to dispose of an asset or assets located outside the UK for less than full market value without incurring a UK tax charge. Any gain was calculated by treating the asset as having been disposed of at market value but it was not possible for the individual to remit that gain as it did not represent money or money’s worth in his hands.


Julian assigns a painting to his trust for nil consideration. Although a gain may have accrued based on the market value of the painting at the date of transfer it was not possible for Julian to remit that gain as no consideration was received.