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Official guidance
Capital Gains Manual

CG39250P · Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Anti-avoidance legislation – flip-flop schemes: TCGA92/Sch4C - attribution of TCGA92/Sch4B gains to beneficiaries - history

  • CG39250 · TCGA92/Sch4C - attribution of TCGA92/Sch4B gains to beneficiaries - history
  • CG39255 · TCGA92/Sch4C - outline
  • CG39260 · Schedule 4C pool
  • CG39265 · Outstanding section 2(2) amounts
  • CG39270 · Amount of Schedule 4B trust gains
  • CG39275 · Further transfer of value in later tax year
  • CG39280 · Attribution of gains to beneficiaries who receive capital payments
  • CG39285 · Charge to tax
  • CG39290 · Schedule 4C pool created before 6 April 2008
  • CG39295 · Definition of relevant settlement
  1. Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Anti-avoidance legislation – flip-flop schemes: TCGA92/Sch4C - attribution of TCGA92/Sch4B gains to beneficiaries - history: contents
  2. Outstanding section 2(2) amounts

CG39265 | Outstanding section 2(2) amounts

From HM Revenue & Customs · Capital Gains Manual

TCGA92/Sch4C/para1A(1)

The outstanding section 2(2) amount as at the end of the year of transfer is calculated as follows:

  • Calculate the section 2(2) amount for the year of transfer.

  • Give effect to the application of TCGA92/S90 (transfers between settlements), CG38910+, to the year of transfer or any earlier year. This applies to transfers from and to the settlement.

  • Apply the ordinary matching rules in TCGA92/S87 to any capital payments made in the year of transfer or any earlier year to identify any unmatched amounts.

  • For the year of transfer only, add back any matched capital payment that is received by a non-UK resident beneficiary who will not be chargeable on the gain.

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