As is the case for UK residents, the capital gains tax rules apply in ascertaining who may be charged to tax on offshore income gains.

Individuals

Gains realised by individuals who are resident or ordinarily resident in the UK but domiciled outside the UK are taxed on a remittance basis (ICTA 1988, s. 761(5), applying TCGA 1992, s. 12).

Gains realised by individuals who are neither resident nor ordinarily resident in the UK are not chargeable.

Trustees and beneficiaries

Gains realised by trustees who are, or a majority of whom are, resident or ordinarily resident outside the UK are not chargeable provided the general administration of the trusts is ordinarily carried on outside the UK (ICTA 1988, s. 761(7)).

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