ARCHIVED: This archived Practice Note reviews the pros and cons for trustees of making a rebasing election under Finance Act 2008, Sch 7 Pt 2, para 126, and sets out the steps required. It further considers rebasing elections under section 3 of the Taxation of Chargeable Gains Act 1992 (TCGA 1992) for gains arising in underlying companies, and TCGA 1992, section 43 on assets traced from other assets and movements between trusts. It also explains the implications of rebasing elections for those using the remittance basis. Abolition of remittance basis from 6 April 2025 The remittance basis for UK-resident, non-domiciled individuals ceased on 6 April 2025. The final year in which it could be claimed is the 2024–25 tax year. From 6 April 2025, a new four-year arrangement—often called the foreign income and gain (FIG) regime—applies, granting 100% relief on eligible FIG to new arrivals during their first four years of UK tax residence, provided they were not UK tax resident in any of the ten tax...

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) ...

Stop Press : Finance Act 2026 (FA 2026) makes two changes to the non-resident capital gains tax rules. FA 2026, s 40 clarifies that, for TCGA 1992, Sch 1AA purposes-namely whether an asset derives at least 75% of its value from UK land and whether the disposer has a substantial indirect interest in UK land-every cell within a protected cell company (PCC) is to be treated as a standalone company. This applies to disposals occurring on and after 26 November 2025. FA 2026, s 41 provides that where (i) a company or individual disposes of an asset deriving at least 75% of its value from UK land, (ii) the disposal has an ‘appropriate connection’ to a collective investment vehicle (CIV) (as defined in TCGA 1992, Sch 5AAA, para 6), and (iii) the gain is exempt under a double taxation treaty, the company or individual need not submit a claim for double tax treaty relief under TIOPA 2010, s 6(2)(a) or (3)(a) for that disposal. ...