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...

Offshore trusts: UK attribution of gains to settlors (TCGA 1992 s86/Sch 5)—scope, residence/domicile, tainting, UK property and company gains, DTTs, recovery, and Finance Act 2025 updates

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Practice notes

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

The Finance Act 2025 (FA 2025), which obtained Royal Assent on 20 March 2025, legislates to end the remittance basis and introduce a residence-based regime from 6 April 2025. FA 2025 also makes residence, rather than domicile, the principal criterion for inheritance tax exposure.

Other amendments include:

Changes to the rules defining excluded property status
Abolition of protected settlements status for offshore trusts
Revisions to overseas workday relief

For details on these measures, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26. See also: Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.

This Practice Note examines the effect of TCGA 1992, s 86 and Sch 5, which attribute the gains of a non-resident settlor-interested trust to the settlor. Before 1991, neither income nor gains of any settlement were attributed to the settlor unless he or his spouse were actual or potential beneficiaries, or obtained a benefit. The Finance Act 1991 introduced Attribution of gains arising in specified offshore settlements to the settlor...

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Web page updated on 27/05/2026

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