Readers’ forum: When does a gain for a property sale accrue?

My client is taxed on the remittance basis. He made a residential property gain in 2023 but the proceeds were remitted to the UK in 2024-25. I’m struggling to understand the tax rate which should be applied to the gain.

F(No 2)A 2024 s 6(1) suggests it should be taxed at 24% but s 6(3) seems to point in the opposite direction. I’ve always taken the view that gains ‘accrued’ in the year of remittance were taxed using the rates in force for the year of remittance. Any other view makes little sense. But s 6(3) clearly says that: ‘the amendments made by this section (being the 24% rate) have effect in relation to disposals made on or after 6 April 2024…’. Hence the confusion as to how a 24% rate can be applied to a pre-2024 disposal.

Sch 1 para 1 only changes the date the gain is...