Skip to content
Solved
SearchBrowse
Sign in

Contents

Official guidance
Capital Gains Manual

CG38730P · Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Charge on beneficiary of non-resident settlement – TCGA92/S87: Years before 2008-09

  • CG38730 · Years before 2008-09 - outline
  • CG38735 · Years before 2008-09 - unmatched trustees’ gains
  • CG38740 · Years before 2008-09 - unmatched trustees’ gains - example
  • CG38745 · Years before 2008-09 - unmatched capital payments
  • CG38750 · Years before 2008-09 - unmatched capital payments - example 1
  • CG38755 · Years before 2008-09 - unmatched capital payments - example 2
  • CG38760 · Matching: non-UK domiciled beneficiaries - events before 2008-09
  • CG38765 · Matching: non-UK domiciled beneficiary - unmatched capital payment for year before 2008 - 09 - example
  • CG38770 · Matching: non-UK domiciled beneficiary - unmatched section 2(2) amount for year before 2008 - 09 - example
  • CG38775 · Matching: non-UK domiciled beneficiary - capital payments received 12 March to 5 April 2008
  1. Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Charge on beneficiary of non-resident settlement – TCGA92/S87: Years before 2008-09: contents
  2. Years before 2008-09 - unmatched capital payments

CG38745 | Years before 2008-09 - unmatched capital payments

From HM Revenue & Customs · Capital Gains Manual

FA08/Sch07/para122

If there is a surplus of capital payments over trustees’ gains for years before 2008-09 it is necessary to identify the year in which the capital payment was received. For years before 2008-09 capital payments that were matched against trustees’ gains were reduced by s87(6) in its original form. This was repealed when FA08 introduced the new matching rules but FA08/Sch07/para122 preserves its effect to establish the starting position in 2008-09. The ordinary matching rules in s87A will then apply to the earlier years.

All of a capital payment matched before 2008-09

If all the capital payments were matched in earlier years they are simply reduced to nil, FA08/Sch07/para122(1), example CG38750.

Only part of a capital payment matched before 2008-09

If only part of a capital payment was matched the payment is reduced by that part, FA08/Sch07/para122(2), example CG38750.

More than one capital payment matched before 2008-09

If capital payments for more than one year were matched but the total capital payments were greater than the trustees’ gains you identify the part of unmatched capital payment on a first in - first out basis, FA08/Sch07/para122(3), example CG38755.

PreviousNext
PrivacyTerms