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HMRC internal manual

Capital Gains Manual

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+.