STOP PRESS: The remittance basis is abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in FA 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.
An outline of the regime applying to offshore funds is discussed in the Offshore funds guidance note, and you are advised to read that guidance note first. It also explains what is meant by ‘reporting’ and ‘non-reporting’ funds.
Reporting funds can be divided into ‘opaque’ funds (also known as non-transparent funds), where investors are regarded as owning units in the fund rather than as owning precise fractions of the underlying assets, and ‘transparent’ funds, where the investor has a share of the underlying fund assets.
The fund manager should be able to tell the taxpayer whether the fund is opaque or transparent for tax purposes.
This guidance note
Outright giftsAn outright gift is the most straightforward type of gift. It simply involves the outright transfer of property from one person to another with no conditions attached.This type of gift is most suitable for clients who want to pass over modest amounts, or give to responsible and capable
Qualifying charitable donationsCompanies can obtain corporation tax relief for qualifying payments or certain transfers of assets to charity under the qualifying charitable donations regime. Definition of qualifying charitable donationThe definition of ‘qualifying charitable donations’
Temporary differencesCalculation of temporary differencesThe temporary difference arising in respect of an asset or liability is calculated by comparing the carrying value of that asset or liability with its tax base.IAS 12 uses the concept of taxable or deductible temporary differences. Whether a