Remittance basis
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
Application
£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
Generally
Identification of disposals
Insolvencies
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
Interpretation
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
Charge
Application
Funds brought in to settle charge
Generally
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
Generally
Losses
Migrant settlements
Reporting limits
Transfer of assets abroad
Transfers between settlements
Unremittable foreign securities income
Claims
Consequences
Effect on personal reliefs
Generally
Individuals
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
Generally
Deductions
Domicile of choice
Double taxation relief, calculation of income and gains
Generally
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
Generally
Employment income, mixed fund rules
30-day deadline
Breaches of the deposit rule
Generally
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
PAYE
Relevant period
SAYE option schemes
Share incentive plans
Employment-related securities, PAYE
Enterprise management incentives
Excluded property trusts
Exemptions
Charge where property ceases to be exempt
Continuation
De minimis exemption
Gains on sale of exempt property
Generally
Personal use exemption
Public access exemption
Re-investment
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
Generally
Historical background
Increased basis charge
Long-term residents
Long-term UK resident
Charge
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
Composition
Employment income
Generally
Identification rules
Overseas workday relief
Specified categories
Tracing rules
Transfers
Money paid to the Commissioners
Nominated income and gains
Non-domiciled beneficiaries
Non-domiciled individuals
Non-domiciliaries
Non-resident will trust
Not applicable for PRs
Not available where deemed domiciled
Offshore funds
Offshore income gains
Order of remittances
Ordinary residence
Commencement
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
Savings
Overseas capital losses
Partnerships
PAYE
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
Generally
Identification rules
Mixed funds
Specified categories
Tracing rules
Reason HMRC would argue individual has UK domicile
Relevant foreign income
Charge on
Deductions from
Meaning
Temporary non-residents
Relevant person, meaning
Remittance of income and gains
Amount remitted
Annual remittance base charge
Anti-avoidance
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
Definitions
Exempt property relief
Foreign chargeable gains other than for full consideration
Generally
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
Settlors
Temporary importation rule
Transfers from mixed funds
Remittance, meaning
Condition A
Condition B
Condition C
Condition D
Generally
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
Generally
Valuation
Withdrawal of relief
US citizens