Paragraph 1 Rebasing of assets for individuals who have been subject to the remittance basis

United Kingdom

(1)

This paragraph applies to the disposal of an asset by an individual (“P”) where—

(a)

the asset was held by P on 5 April 2017,

(b)

the disposal is made on or after 6 April 2025,

(c)

the asset was not situated in the United Kingdom at any time in the period beginning with 6 March 2024 and ending with 5 April 2025,

(d)

P was not domiciled in the United Kingdom at any time in a tax year before tax year 2025-26, and

(e)

P has made a claim under section 809B of ITA 2007 (claim for remittance basis) for at least one tax year that is—

(i)

one of the tax years from tax year 2017-18 to tax year 2024-25, and

(ii)

a tax year for which neither section 809D nor 809E of that Act applied to P (remittance basis applies without claim).

(2)

In computing, for the purpose of TCGA 1992, the gain or loss accruing on the disposal, it is to be assumed that P acquired the asset on 5 April 2017 for a consideration equal to its market value on that date.

(3)

Sub-paragraph (2) applies notwithstanding section 58 (1) of TCGA 1992 (disposals between spouses).

(4)

Where under section 127 of TCGA 1992 (including that section as applied by sections 132, 135 and 136 of that Act) an original and a new holding of shares or other securities are treated as the same asset, the condition in sub-paragraph (1)(c) applies to both the original and the new holding.

(5)

Section 835BA of ITA 2007 (deemed domicile) applies for the purposes of sub-paragraph (1)(d).

(6)

This paragraph and paragraphs 2 and 3 have effect as if they were included in TCGA 1992.