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Home / Simons-Taxes /Personal and employment tax /Part E6 Overseas issues /Division E6.3 Domicile and the remittance basis /The remittance basis / E6.328 The remittance basis—mixed funds rules
Commentary

E6.328 The remittance basis—mixed funds rules

Personal and employment tax

For the latest New Development, see ND.2751.

A remittance may be made to the UK from a mixed fund, which is money or other property which, immediately before the transfer, contains or derives from more than one of the kinds of income and capital set out in (a)–(i) below, or income or capital for more than one tax year1. A typical example of a mixed fund would be a bank account in which an individual holds different types of income, such as bank interest, dividends and earnings, or gains. Another example of a mixed fund is an asset purchased using a mixture of income, gains and capital.

Statutory rules determine the order in which the elements of a mixed fund are treated as remitted to the UK. The mixed funds rules are discussed in HMRC's manual at RDRM35210–RDRM35330.

The commentary below considers the mixed fund rules that apply from 6 April 2008 onwards. These rules do not apply to remittances from a mixed fund where the foreign income or gains arose to a remittance

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