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HMRC internal manual

Capital Gains Manual

Arrival in and departure from UK: temporary non-residence: assets acquired by an offshore trust or close company - year of departure 2012-13 or earlier

The exclusion from charge, see CG26230, for assets acquired after the taxpayer’s departure does not apply to assets acquired within an offshore trust, TCGA92/S86 or TCGA92/S87 or by a non-resident closely controlled company, TCGA92/S13.