Accrued income profits

Accrued income scheme

Alternative basis of charge

Amount remitted

Amounts not treated as remitted before relevant income/gains have arisen/accrued

Annual exemption, interaction

Anti-avoidance provisions, arrangements which change the composition of mixed funds


£2,000 de minimis rule

Without claims

Attribution of gains to beneficiaries

Blind person's allowance

Business investment exemption

Appropriate mitigation steps

Certificates of tax deposit, use of

Commercial trades

Effect of mitigation steps


Identification of disposals


Potentially chargeable events

Qualifying investments

Qualifying investments out of mixed funds

Repatriation of surplus remittances

Retention of funds to meet capital gains liabilities

Withdrawal of exemption

Business investment relief

Appropriate mitigation steps

Capital gains tax liability, retention of funds to meet

Condition A

Condition B

Disposal proceeds, meaning

Failure to invest within 45 days

Grace period

Income or gains treated as remitted


Mixed funds, investments made from

Money or other property used to make investments

Order of disposals etc.

Potentially chargeable event, meaning

Qualifying investments

Retention of funds to meet capital gains tax liability

Taking proceeds offshore or investing them

Tax deposits, cases involving

Temporary importation rule

Capital gains tax annual exemption



Funds brought in to settle charge


Long-term residents

Nominated income and gains

Payment, remittance of funds

Pre-6 April 2012

Relevant tax increase

US citizens

Chargeable gains

Annual exempt amount

Beneficiaries, attribution of gains to

Foreign currency bank accounts, disposals of debts



Migrant settlements

Reporting limits

Transfer of assets abroad

Transfers between settlements

Unremittable foreign securities income



Effect on personal reliefs



Long-term UK resident

Loss of personal allowances/reliefs

Remittances in later years

Subsequent years

Who may claim

Companies, unremittable overseas income

Controlled foreign companies



Domicile of choice

Double taxation relief, calculation of income and gains


Withholding tax

Effect on what is chargeable

Eligibility for

Employee not ordinarily resident

Employee resident and section 26 compliant

Basis of apportionment

HMRC guidance

Period before April 2008

Employment income

Delayed remittances


Employment income, mixed fund rules

30-day deadline

Breaches of the deposit rule


Qualifying accounts

Employment-related securities

Artificially enhanced market value

Associated employment performed in UK, limit of foreign securities income

Avoidance of a UK taxable presence

Effect of

Foreign securities income, determination

Just and reasonable apportionment, foreign securities income


Relevant period

SAYE option schemes

Share incentive plans

Employment-related securities, PAYE

Enterprise management incentives

Excluded property trusts


Charge where property ceases to be exempt


De minimis exemption

Gains on sale of exempt property


Personal use exemption

Public access exemption


Repair or restoration exemption

Sale and re-investment

Taking offshore

Temporary importation exemption

Three other effective exemption

Foreign service

Foreign source pensions, temporary non-residents


Historical background

Increased basis charge

Long-term residents

Long-term UK resident


Nomination of income and gains

Loss relief denied

Low-income employees working in the UK, exemption

Married couples and civil partners

Migrant or seasonal workers in the UK, exemption

Mixed funds

Arrangements changing, anti-avoidance provisions


Employment income


Identification rules

Overseas workday relief

Specified categories

Tracing rules


Money paid to the Commissioners

Nominated income and gains

Non-domiciled beneficiaries

Non-domiciled individuals


Non-resident will trust

Not applicable for PRs

Not available where deemed domiciled

Offshore funds

Offshore income gains

Order of remittances

Ordinary residence


Consequential amendments

Disguised remuneration

Employee non-resident

Foreign chargeable gains

Foreign securities income

Life assurance premiums

Non-domiciliaries, restriction to

Relevant foreign earnings

Removal benefits and expenses


Overseas capital losses



Payments on account

Pension schemes, temporary non-residents

Pensions charged on an arising basis, backdated

Person liable under s. 733C or 733E

Personal allowances

Quantifying the remittance

Amount remitted

Amounts not treated as remitted before relevant income/gains have arisen/accrued

Arrangements which change the composition

Composition of mixed funds


Identification rules

Mixed funds

Specified categories

Tracing rules

Reason HMRC would argue individual has UK domicile

Relevant foreign income

Charge on

Deductions from


Temporary non-residents

Relevant person, meaning

Remittance of income and gains

Amount remitted

Annual remittance base charge


Capital gains tax advantage, anti-avoidance

Composition of mixed funds

Consideration for certain services

Dealings where connected operations

Deemed not to be remitted before time treated as arising or accruing


Exempt property relief

Foreign chargeable gains other than for full consideration


Gift recipients, qualifying property and enjoyment

Income tax advantage, anti-avoidance

Meaning of foreign income and gains etc.

Money paid to commissioners

Notional remitted amount

Personal use rule

Property ceasing to be exempt

Property treated as not remitted

Public access rule

Relevant person, meaning

Remitted to the UK, meaning

Repair rule


Temporary importation rule

Transfers from mixed funds

Remittance, meaning

Condition A

Condition B

Condition C

Condition D


Gift recipient, condition C

Qualifying property, condition C

Relevant debts

Specified conditions

Removal expenses and benefits

Rental income from overseas lettings

Reporting funds

Restrictive undertakings

Sales of exempt property, exemption from tax

Chargeable gains accruing on sales

Conditions to be met

Continuation of exemption after sale

Extension of time limits

Seafarer's earnings

Settlor-interested trusts

Special mixed funds rules

Breach of the deposit rule

Detail of special rules

HMRC frequently asked questions

Period of the qualifying account

Qualifying accounts

Remedy of the breach

Third party payments of money/transfer of assets

Transfer of assets abroad

Transitional provisions

Transitional rule for individuals not ordinarily resident at the end of 2012/13 tax year

Travel expenses abroad

Trust income treated as non-savings income

Unremittable income

£2,000 de minimis rule

Claim for relief

Export Credit Guarantee Department, payments by



Withdrawal of relief

US citizens