It has become increasingly common to meet clients who have sold non-UK mutual funds, ETFs and other non-UK investments where the gain needs to reported as an “offshore income gain”.
I was recently at one of those conferences where brilliant tax lawyers were explaining complicated bits of UK tax law; and I am sure I heard an eminent authority say that the CGT share matching rules (Taxation of Chargeable Gains Act (TCGA) 1992, s104) do not apply to offshore income gains.
Is this correct? If so, what are the share matching rules for disposals that give rise to an offshore income gain?
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