Powered by Lexis+®
Jurisdiction(s):
United Kingdom
CASE STUDY

“In some areas of research there were also significant time savings. You get to what you are looking for more quickly, which all goes to the value of the product.”

Harper Mcleod

Access all documents on Mixed fund cleansing

Mixed fund cleansing meaning

What does Mixed fund cleansing mean?
The practical process of reorganising an offshore “mixed fund” so that clean capital, foreign income and foreign chargeable gains are separated for UK remittance basis purposes. Mixed fund cleansing (also called cleansing relief) was a temporary statutory facility, introduced by Finance (No. 2) Act 2017, available between 6 April 2017 and 5 April 2019. It allowed individuals who had used the remittance basis to move monies between their own overseas accounts and, for those transfers, to identify the amounts as clean capital, foreign income or foreign gains, disapplying the normal mixed fund ordering rules. Key features included: offshore-to-offshore transfers only; amounts had to derive from a mixed fund held as at 5 April 2017; robust records were required. It could not be used for funds already brought to, or kept in, the UK, nor to reclassify UK income or UK gains. The practical significance was to ring‑fence clean capital for tax‑free remittance to the UK and to manage future remittances efficiently. Usage and effect were consistent across England & Wales, Scotland and Northern Ireland under UK income tax law and HMRC guidance. Ireland operates a separate remittance basis regime and had no equivalent statutory cleansing window, though prospective segregation of funds remains...
Speed up all aspects of your legal work with tools that help you to work faster and smarter. Win cases, close deals and grow your business–all whilst saving time and reducing risk.

View the related Practice Notes about Mixed fund cleansing

PRACTICE NOTES
UK deemed domicile (2017–2025): IHT, income tax and CGT regime—15/20-year rule, formerly domiciled residents, transitional rules, split years, asset rebasing and mixed-fund cleansing

An individual is treated as UK domiciled where, although they are domiciled outside the UK under the common law principles outlined in Practice Note: Domicile for UK tax purposes before 6 April 2025 [Archived], a statutory rule nevertheless treats them as domiciled for one or more tax purposes. This Practice Note looks only at the deemed domicile provisions that came into force on 6 April 2017, and insofar as they apply to individuals. For details of the deemed domicile rules in place before that date, see Practice Note: Deemed domicile for tax before 6 April 2017 [Archived]. In contrast to domicile at common law, deemed domicile is not inherited from parent to child. For information on the regime brought in by the Finance Act 2013 allowing a non-UK domiciled spouse or civil partner of a person domiciled in the UK to elect to be treated as UK domiciled for IHT purposes, see Practice Note: IHT issues for mixed domicile spouses and civil partners before 6 April 2025 [Archived]. For guidance...

Read More Right Arrow
PRACTICE NOTES
Private Client Glossary (England and Wales): Wills, Probate, Trusts, Capacity and UK Taxation

Private Client England & Wales glossary A Abatement When, after settling the deceased’s funeral costs, debts and liabilities, the remaining estate cannot satisfy all legacies in full, the gifts are reduced accordingly, unless the Will shows a different intention. In a solvent estate, the order for reduction appears in Part II of Schedule 1 to the Administration of Estates Act 1925. Refer to Practice Note: Payment of legacies. Accruals basis Where income is taxed on an accruals basis, it is attributed to a given tax year by reference to the number of days within that year during which the activity giving rise to the liability accrued. See Practice Note: What is the basis of income tax?. Accumulation and maintenance (A&M) trust A form of non‑interest in possession trust designed to benefit children and young people up to 25, which received favourable inheritance tax treatment between 1975 and 2006. See Practice Note: Accumulation and maintenance trusts—IHT [Archived]. Accredited Legal Representative (ALR) ...

Read More Right Arrow
PRACTICE NOTES
UK remittance basis: mixed funds under ITA 2007—definition, ordering rules for Conditions A and B, offshore transfers, cleansing, pre-FA 2008 and anti-avoidance [Archived]

ARCHIVED: This archived Practice note addresses mixed funds in the context of the remittance basis. It reviews: the statutory meaning of ‘mixed fund’ in section 809Q(6) of the Income Tax Act 2007 when a movement from a mixed fund is treated as a transfer the steps for determining the make-up of a remittance (arising under Conditions A and B) drawn from a mixed fund STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime Finance Act 2025 (FA 2025), which obtained Royal Assent on 20 March 2025, introduces the abolition of the remittance basis of taxation and its replacement with a residence-based regime from 6 April 2025. FA 2025 also substitutes domicile as the key determinant of inheritance tax liability with residence. Additional reforms include revising the rules for excluded property status, removing protected settlements status for offshore trusts, and changes to overseas workday relief. For further information, see Practice Notes: The abolition of the remittance basis of...

Read More Right Arrow