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Legislation
Finance Act 2026

Crossheading Other international matters

  • Section 46 Unassessed transfer pricing profits
  • Section 47 Transfer pricing reform
  • Section 48 International controlled transactions
  • Section 49 Permanent establishments
  • Section 50 Pillar two
  • Section 51 Controlled foreign companies: interest on reversal of state aid recovery
  • Section 52 Offshore income gains
  • Section 53 Offshore income gains: savings
  1. Other international matters
  2. Offshore income gains

Section 52 | Offshore income gains

From legislation.gov.uk

(1)In the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)—

(a)in regulation 20 (application to gains of non-resident settlements), omit paragraphs (2) to (5);

(b)in regulation 21 (application of transfer of assets abroad provisions), omit paragraphs (4) to (6).

(2)In consequence of the amendments made by subsection (1)—

(a)in section 734 of ITA 2007 (reduction in amount charged: previous capital gains tax charge), in subsection (5), omit “20 and”;

(b)in Schedule 7 to FA 2008 (remittance basis), omit paragraphs 100 to 102;

(c)in the Offshore Funds (Tax) Regulations 2009—

(i)in regulation 18 (charge to tax on disposal of asset: further provisions), in paragraph (5), omit sub-paragraph (c);

(ii)in regulation 19 (income treated as arising under regulation 17: remittance basis), omit paragraph (5);

(iii)omit regulation 130 (amendments of FA 2008);

(iv)in Part 2 of Schedule 3 (index of defined expressions), omit the entry for “OIG amount”;

(d)in Schedule 10 to FA 2025 (temporary repatriation facility)—

(i)in paragraph 3(7), for “paragraphs 4 and 5” substitute “paragraph 5”;

(ii)in paragraph 3(9), for “paragraphs 4 and 5” substitute “paragraph 5”;

(iii)omit paragraph 4;

(iv)in paragraph 5(7), for “paragraphs 3 and 4” substitute “paragraph 3”;

(v)in paragraph 10, omit sub-paragraphs (7) and (8).

(3)Section 53 makes provision preserving in certain cases the effect of the law as it applied before the amendments made by this section.

(4)This section—

(a)is to be treated as having come into force on 6 April 2025;

(b)has effect for the tax year 2025-26 and subsequent tax years.

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