My client holds an investment in an offshore fund that will when she cashes it in give rise to a substantial offshore income gain. She is considering giving the whole thing to a UK charity. That would not qualify for gift aid but as far as I can see it would exempt the offshore income gain because that is calculated using CGT rules – and a disposal to charity is at a ‘no loss/no gain’ value. Am I missing anything?
The alternative would be to receive the money give 80% of it to the charity pay 20% to HMRC and claim gift aid – but that seems much more complicated.
If it does avoid those complications to give it directly is it enough simply to declare that she has transferred beneficial ownership to the charity? It may not be possible to...
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