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HMRC internal manual

Capital Gains Manual

Effects of residence, ordinary residence and domicile: introduction

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

  • The individual may be resident or ordinarily resident* in the UK


  • although the individual is neither resident nor ordinarily resident* in the UK, he or she carries on a trade, profession or vocation in the UK through a branch or agency.

This general scheme is affected in some circumstances by the domicile of the individual and the effects of double taxation treaties.

  • For 2013/14 and subsequent years ordinary residence does not need to be considered.