CG10710 - Persons chargeable: on chargeable gains of others

TCGA92/S13*, TCGA92/S86 & TCGA92/S87

There are special provisions for attributing:

• The gains accruing to a closely controlled non-resident company to UK resident members of that company, see CG13500+.
• The gains accruing to the trustees of non-resident settlements to a UK domiciled and resident settlor, see CG38430, or UK resident beneficiaries who receive capital payments from the trustees, see CG38570c.

All liability in respect of non-resident trusts is dealt with by HMRC Charities, Savings and International, Bootle and other specialist compliance offices. Any case identified in a responsible office should be reported to HMRC Charities, Savings and International, Bootle, see CG38400+.

*There provisions were re-written for disposals from 6 April 2019 see CG10150