PART 2THE TREATMENT OF PARTICIPANTS IN NON-REPORTING FUNDS
CHAPTER 2CHARGES TO TAX ON PARTICIPANTS IN NON-REPORTING FUNDS
Charge to tax on disposal of asset
Income treated as arising under regulation 17: remittance basis19
1
This regulation applies to income treated as arising under regulation 17 to an individual in a tax year if—
a
section 809B, 809D or 809E of ITA 2007 M1 (remittance basis) applies to the individual for that year, and
b
the individual is not domiciled in the United Kingdom in that year.
2
The income is treated as relevant foreign income of the individual.
3
For the purposes of Chapter A1 of Part 14 of ITA 2007 M2 (remittance basis)—
a
any consideration obtained on the disposal of the asset is treated as deriving from the income, and
b
unless the consideration so obtained is of an amount equal to or exceeding the market value of the asset, the asset is treated as deriving from the income.
4
In paragraph (3)—
a
“the asset” means the asset the disposal of which causes the income to be treated as arising, and
b
“the disposal” means the disposal mentioned in sub-paragraph (a) of that paragraph.
5
This regulation does not apply for the purposes of regulation 20.