Taxation of Chargeable Gains Act 1992 Schedule 4C paragraph 8

Attribution of Schedule 4C gains to beneficiaries

Schedule 4C paragraph 8 sets out how chargeable gains arising in the Schedule 4C pool are attributed to beneficiaries of a relevant settlement by matching those gains against capital payments the beneficiaries have received.

• Capital payments received by UK-resident beneficiaries from a relevant settlement are matched against gains held in the Schedule 4C pool, and the matched amount is treated as a chargeable gain accruing to the beneficiary in the relevant tax year.
• The chargeable gain equals the full capital payment if it is wholly matched, or the matched portion if only partly matched.
• Gains in the Schedule 4C pool take priority and are matched before ordinary section 87 gains, but offshore income gains (if any) are matched before Schedule 4C pool gains.
• Special rules that re-attribute capital payments to someone other than the actual recipient (such as the settlor or a recipient of an onward gift) also apply to Schedule 4C matching, subject to certain payments being disregarded under paragraph 9.