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Home / Simons-Taxes /IHT, trusts and estates /Part I5 Settled property /Division I5.12 Income tax and CGT for non-resident settlements /Liability of beneficiaries—capital gains tax / I5.1243 Attribution of settlement gains—disregard of certain capital payments to non-residents
Commentary

I5.1243 Attribution of settlement gains—disregard of certain capital payments to non-residents


IHT, trusts and estates

Disregard of capital payments—overview

In certain situations, from 2018/19, a capital payment may be 'disregarded', ie ignored, when determining how it should be matched with settlement gains (see I5.1245).

These disregards apply when capital payments are made to:

  1. Ìý

    •ÌýÌýÌýÌý a beneficiary who is non-UK resident for the whole of the tax year1, or

  2. Ìý

    •ÌýÌýÌýÌý a migrating beneficiary2

There are specific provisions where the capital payment is:

  1. Ìý

    •ÌýÌýÌýÌý made during a period of the beneficiary's temporary non-residence3 (see below)

  2. Ìý

    •ÌýÌýÌýÌý made to a close family member of the settlor4 (see I5.1244)

  3. Ìý

    •ÌýÌýÌýÌý received by a beneficiary and then paid onto another person5 (see I5.1244)

Disregard of capital payments to non-residents

Where a beneficiary who is non-UK resident for the whole of the tax year receives

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Web page updated on 17 Mar 2025 17:09