Statement of Practice D23
Published 1 January 1978
© Crown copyright 1978
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Where a UK participator in a non-resident company which would be a close company if resident in the UK is chargeable to Capital Gains Tax on a proportion of a capital gain accruing to that company, tax credit relief may be given against UK Capital Gains Tax for the appropriate proportion of any overseas tax payable by the company in the country where it is resident in respect of its gain under Taxation of Chargeable Gains Act (TCGA) 1992 section 277, alternatively, under TCGA 1992 section 278, the appropriate proportion of the overseas tax may be deductible in computing the participator’s gains to the extent that the overseas tax has not qualified for relief under TCGA 1992 section 277.
Note: this statement was amended by IR 131 Supplement (November 1998).