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Hi I am a Canadian citizen living / working in Toronto, Canada. I will be permanently moving to the UK in 3 months’ time. I have funds in Canadian RRSP (Registered Retirement Savings Plan) in Canada and I plan to withdraw those when I become a resident of the UK. Canada and UK have Double Taxa

and specifically around withdrawal of RRSP, I found the following circular from the UK govt. (DT4617)

www.gov.uk/hmrc-internal-manuals/double-taxation-relief/dt4617

The manual is adequately clear on the withholding tax of 25% levied by Canada upon withdrawal, however, I am not clear on the treatment of any capital gains in those RRSP when I file my taxes as a UK resident. My questions are as follows:

I plan to relocate permanently by March 2019 and become a UK tax resident for the purpose of filing the 2019 taxes. I have 2 options for lump sum withdrawal:

1. I continue to maintain the funds in RRSP until 2020 at which point I withdraw lump-sum. After paying 25% to Canada, I file UK tax in 2020. How are the capital gains (for UK tax) calculated? Are they calculated on the cost of purchase of assets from the beginning (Some of the RRSP assets were purchased 8-9 years earlier and therefore, may have significant taxable capital gains)? It appears that the last line of DT4617 manual specifies that “if the assets are disposed to fund withdrawal’ capital gains tax is attracted.

2. In the event, I sell the assets in the RRSP and converting them into cash while still being in Canada, and then later after moving to the UK withdraw that cash, technically speaking, assets would not be sold to fund the withdrawal. Would I then be able to not pay capital gains taxes in the UK since assets were sold while I was in Canada and not to fund the withdrawal at the time. This essentially has the impact of changing the ‘cost basis’ of those assets.

Any advice on the aforementioned will be much appreciated. If there are any specific HMRC links that address this or any tax accountants in the UK who could address this, please advise.

Thanks..!
JD
Canada Capital Gains Tax

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