{
  "url": "https://openlegislation.uk/finance-act-2025/schedule-10/paragraph-15",
  "json_url": "https://openlegislation.uk/finance-act-2025/schedule-10/paragraph-15.json",
  "legislation": "ukpga/2025/8",
  "legislation_title": "Finance Act 2025",
  "legislation_url": "https://openlegislation.uk/finance-act-2025",
  "path": "schedule/10/paragraph/15",
  "kind": "paragraph",
  "number": "15",
  "heading": "Mixed funds: section 809Q of ITA 2007",
  "text": "(1) Section 809Q of ITA 2007 is amended as follows.\n(2) In subsection (3)—\n(a) before Step 1 insert—\n“Step A1\nFind the amount (if any) of income or capital of the individual for the relevant tax year in the mixed fund immediately before the transfer that is TRF capital.\nIf the amount of the transfer is equal to, or less than, the amount of TRF capital, treat the transfer as containing only TRF capital.\nOtherwise—\n(a)treat so much of the transfer as does not exceed the amount of the TRF capital as being comprised of TRF capital, and\n(b)apply the following steps to the remainder of the transfer.”, and\n(b) in Steps 2 to 4, and in the first sentence in Step 5, for “transfer”, in each place it occurs, substitute “remainder”.\n(3) In subsection (6)—\n(a) omit the “or” after paragraph (a), and\n(b) after paragraph (b) insert\n“, or\n(c) income or capital that is TRF capital and income or capital that is not TRF capital.”\n(4) After subsection (8) insert—\n“(9) For the purposes of this Chapter “TRF capital” means any amount that—\n(a) is qualifying overseas capital (within the meaning of Part 1 of Schedule 10 to FA 2025) as a result of paragraph 2 of that Schedule, and\n(b) is designated qualifying overseas capital for the purposes of that Part of that Schedule (and see paragraph 8(7) which provides for qualifying overseas capital to be treated as designated qualifying overseas capital from the start of the tax year to which the return in which it is designated relates).”\n(5) In section 809Z10 of ITA 2007 (general interpretation), after the definition of “the remittance basis user” insert—\n““TRF capital” has the meaning given by section 809Q(9).”",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2025/8/schedule/10/paragraph/15",
    "retrieved_at": "2026-10-29T08:47:01.939707+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}