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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Remittance Basis: Remittance Basis up to 6 April 2008: Mixed Funds: Overview

A mixed fund is an overseas fund of money and/or other property which contains, or consists of more than one type of income, or income and capital and gains. A typical example is a bank account into which different types of income, such as bank interest, dividends and earnings, or gains are paid.

The mixed fund rules do not apply where a taxpayer arranges that different forms of income are held in separate accounts.

Proceeds from a disposal of an asset that contain a capital gain are instantly a ‘mixed fund’ of capital and gain.