Where the foreign income or gains arose to a remittance basis user before the introduction of the current remittance basis rules on 6 April 2008, the so-called 'common law matching rules' arising from case law apply to determine what has been remitted from a mixed fund1. A mixed fund is a bank account or the proceeds from the disposal of a chargeable asset that contain different types of income or gains. A mixed fund may also include 'clean capital', which are amounts that can be remitted to the UK without triggering a remittance.
It is possible that an individual could remit pre-April 2008 income or gains in a current tax year. This is because whether or not the individual is taxable on the remittance basis in the tax year of remittance is irrelevant. Even if the individual is taxed on the arising basis, any foreign income or gains remitted to the UK in that year that arose in an earlier
Web page updated on 17 Mar 2025 13:37
