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HMRC internal manual

Capital Gains Manual

Effects of residence/domicile: introduction and layout of instructions

Broadly the legislation aims to charge Capital Gains Tax on gains where there is an appropriate connection between the person realising the gain and the UK. The connection may be one of two types.

  • The person may be resident or ordinarily resident* in the UK.
  • Although the person is neither resident nor ordinarily resident in the UK, the person carries on a trade, profession or vocation in the UK through a branch or agency or, in the case of a company, through a permanent establishment.

This general scheme is affected by the domicile of individuals and the effects of double taxation treaties.

  • Ordinary residence is not considered for 2013/14 and later years.

The following paragraphs tell you more about the rules applying for

  • individuals, see CG10920-CG10940
  • companies, see CG10950
  • settlements, see CG10960
  • persons arriving in or leaving the UK, see CG10970-CG10976
  • partnerships controlled abroad, see CG11000
  • certain gains arising to non-resident companies and non-resident trusts, see CG11020-CG11030
  • exemption from charge under double taxation treaties, see CG11040.