Legislation – Finance Act 2026
Changes to legislation:
Finance Act 2026, Section 52 is up to date with all changes known to be in force on or before 18 April 2026. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.![]()
Changes to Legislation
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Part 1Income tax, capital gains tax and corporate taxes
Other international matters
52Offshore income gains
(1)
In the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)—
(a)
in regulation 20 (application to gains of non-resident settlements), omit paragraphs (2) to (5);
(b)
in regulation 21 (application of transfer of assets abroad provisions), omit paragraphs (4) to (6).
(2)
In consequence of the amendments made by subsection (1)—
(a)
in section 734 of ITA 2007 (reduction in amount charged: previous capital gains tax charge), in subsection (5), omit “20 and”;
(b)
in Schedule 7 to FA 2008 (remittance basis), omit paragraphs 100 to 102;
(c)
in the Offshore Funds (Tax) Regulations 2009—
(i)
in regulation 18 (charge to tax on disposal of asset: further provisions), in paragraph (5), omit sub-paragraph (c);
(ii)
in regulation 19 (income treated as arising under regulation 17: remittance basis), omit paragraph (5);
(iii)
omit regulation 130 (amendments of FA 2008);
(iv)
in Part 2 of Schedule 3 (index of defined expressions), omit the entry for “OIG amount”;
(d)
in Schedule 10 to FA 2025 (temporary repatriation facility)—
(i)
in paragraph 3(7), for “paragraphs 4 and 5” substitute “paragraph 5”
;
(ii)
in paragraph 3(9), for “paragraphs 4 and 5” substitute “paragraph 5”
;
(iii)
omit paragraph 4;
(iv)
in paragraph 5(7), for “paragraphs 3 and 4” substitute “paragraph 3”
;
(v)
in paragraph 10, omit sub-paragraphs (7) and (8).
(3)
Section 53 makes provision preserving in certain cases the effect of the law as it applied before the amendments made by this section.
(4)
This section—
(a)
is to be treated as having come into force on 6 April 2025;
(b)
has effect for the tax year 2025-26 and subsequent tax years.