# Finance Act 2025, Paragraph 16: Mixed funds: section 809R of ITA 2007

Extent: E+W+S+N.I.

(1) Section 809R of ITA 2007 is amended as follows.
(2) In subsection (1), for “This section applies” substitute “Subsections (2) to (8) apply”.
(3) After subsection (4) insert—
“(4A) For the purposes of subsection (4)—
(a) TRF capital is to be treated as a kind of income or capital, and
(b) TRF capital is not to be regarded as any other kind of income or capital.”
(4) In subsection (5) for “section 809Q does not apply” substitute “neither section 809Q nor section 809RZA(2) applies”.
(5) In subsection (6)—
(a) in the words before paragraph (a), for “section 809Q as not applying in relation to it, if it” substitute “neither section 809Q nor section 809RZA(2) as applying in relation to it, if they”, and
(b) in paragraph (a), for “section 809Q does not apply” substitute “neither section 809Q nor section 809RZA(2) applies”.
(6) In subsection (7)—
(a) omit the “or” after paragraph (a), and
(b) after paragraph (b) insert
“, or
(c) income or capital that is TRF capital and income or capital that is not TRF capital.”
(7) In subsection (9)—
(a) for “step 1” substitute “steps A1 and 1”, and
(b) for “step 2” substitute “steps A1 and 2”.

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Source: https://www.legislation.gov.uk/ukpga/2025/8/schedule/10/paragraph/16 (the official version)
Page: https://openlegislation.uk/finance-act-2025/schedule-10/paragraph-16
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.