RDRM35810 - Remittance basis: Amounts remitted: Special mixed funds: Overview

From 6 April 2025 the special mixed fund rules no longer apply. All existing qualifying accounts ceased to be qualifying accounts on 6 April 2025, because an individual will have no general earnings within section 26(1) ITEPA 2003 for 2025-26 or a later tax year. This is due to section 26(1) requiring that the general earnings relate to a year in which the individual is subject to the remittance basis, and the remittance basis of taxation is not available from 2025-26 onwards.

Therefore, previous qualifying accounts (that contain more than just one type of income or capital from one tax year) are ordinary mixed fund accounts from 6 April 2025 onwards. The ending of the special mixed fund rules does not prevent the foreign income and gains within previous qualifying accounts from being designated under the temporary repatriation facility (TRF) 바카라 사이트“ see RDRM71000, or prevent the annualised basis applying to the account for the TRF period where it contains TRF capital 바카라 사이트“ see RDRM75500.

Prior to 6 April 2013 individuals who carried out some of their employment duties in the UK needed rules to determine whether general earnings remitted to the UK related to those duties performed in the UK or duties abroad. This was covered by Statement of Practice 1/09 (SP 1/09) which allowed a relaxation of the mixed fund rules at sections 809Q and 809R ITA 2007 if certain conditions were met.

From 6 April 2013 to 5 April 2025 an individual who claimed the remittance basis of taxation and had general earnings from an employment for a tax year and, those earnings included both general earnings within section 15 (UK duties) and section 26 (non-UK duties) ITEPA 2003, could apply the special mixed fund rules if certain conditions were met.  

The legislation applied to earnings and transfers from a mixed fund of such earnings for tax years 2013-14 to 2024-25 and only employees who were entitled to overseas workday relief (OWR) under the pre-6 April 2025 OWR rules could apply the special mixed fund rules.

From 6 April 2017 individuals who wished to claim OWR were required to check whether they were caught by the deemed domicile provisions Condition A and Condition B.

Individuals who were caught by Condition A were not able to claim the remittance basis and so were unable to claim OWR and the special mixed fund provisions.