Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Attribution definition

What does Attribution mean? Attribution describes, in environmental liability practice, how responsibility for remediating contamination is allocated between different groups of liable parties. In England and Wales, the concept is used in statutory guidance under Part 2A of the Environmental Protection Act 1990: regulators identify “liability groups” of “appropriate persons” (Class A polluters; Class B owners/occupiers) for each significant pollutant linkage, then attribute responsibility between those groups. apportionment is a separate step that divides liability between members within a liability group. The attribution outcome informs who must carry out or fund remediation, the content of remediation notices or voluntary agreements, and subsequent...

UK charge on attributed gains from non‑UK resident companies: conditions, apportionment, exceptions, reliefs, losses, groups, double tax and non‑domiciled individuals (TCGA 1992 s 3; formerly s 13)

Published by a LexisNexis Tax expert

Practice notes

FORTHCOMING CHANGE relating to the reform of offshore anti-avoidance legislation:

On 21 July 2025, HMRC released a summary of responses to its call for evidence on personal tax offshore anti-avoidance legislation, following a consultation that ran from 30 October 2024 to 19 February 2025. The call for evidence sought high-level input across a number of legislative areas, including the Rules attributing gains to participators in non-UK companies. In publishing the outcome, the government notes it will consider how best to engage further with relevant experts to shape and advance additional consultation across this area as a whole, with an update to be provided at the Autumn Budget 2025. Any legislative changes arising from this consultation are not expected to apply before the 2027–28 tax year, at the earliest. For further details, see News Analysis: Legislation Day: Draft Finance Bill 2026—Private Client analysis. This Practice Note concerns the rules that may impose a tax charge on UK persons who hold interests in a non-UK resident Company where that company disposes of an asset and realises a capital gain. What are the Attribution of gains rules?...

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

Web page updated on 22/05/2026

Popular documents

Using the Judicial College Guidelines to assess general damages in personal injury claims

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

Tomlin orders in England and Wales: CPR guidance on drafting, confidentiality, approval, variation, enforcement, limitation, CCA issues, court-specific requirements, sample wording and precedents

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Precedent: Deed of Surrender of Lease with Optional Premium, Settlement and Release, Landlord, Mortgagee and Guarantor Consents, Reimbursement and HM Land Registry Provisions (England and Wales)

Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

Precedent Statutory Declaration: Standard Wording under the Statutory Declarations Act 1835

I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...