IFM37321 - Foreign chargeable gains: Apportionment: Overview

Apportionment

If an individual performs investment management services both inside and outside the United Kingdom, a portion of the gain may be classed as a foreign chargeable gain. Any such treatment should be on a just and reasonable basis and will depend on the particular facts of the matter.

A focus will be given to the investment management services performed by the individual fund manager. In some cases an apportionment of the gain based on days may be acceptable whilst in situations where more significant management duties are consistently performed in one territory, a more well-defined method may be required to avoid understating or overstating the foreign chargeable gain accrued.