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RDRM35230 | Remittance Basis: Amounts Remitted: Mixed Funds: Remittances from mixed funds

From HM Revenue & Customs · Remittance Basis and Domicile Manual

The provisions at sections 809Q and 809R ITA 2007 work together to determine whether, in what amounts (and how) transfers from mixed funds are chargeable to UK tax as remittances.

A taxable remittance from a mixed fund is made where:

  • property (including money) is brought to, received or used in the UK by or for the benefit of a relevant person

  • property (including money) is used outside the UK for the benefit of a relevant person in the UK or in respect of a relevant debt

  • a service is provided in the UK to or for the benefit of a relevant person

and the property, service or consideration for the service is, or derives in some way (directly or indirectly, in whole or in part) from, foreign income or gains within a mixed fund.

See RDRM33100 for guidance on remittances that meet Conditions A and B of section 809L ITA 2007 and for the quantification of amounts remitted see RDRM35005.