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HMRC internal manual

Capital Gains Manual

Non-resident trustees

For the income tax treatment see TSEM3416.

If the trustees are not resident in the UK during the year, the special treatment does not apply to their chargeable gains, FA2005/S30(1)(c). There is no specific provision for chargeable gains arising from the disposal by trustees of assets used for the purposes of a UK branch or agency. (TCGA92/S10).