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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Administration: introduction: non-resident companies

TCGA92/S10(B)

A company which is not resident in the United Kingdom will only be within the charge to Corporation Tax if it carries on a trade here through a permanent establishment, see INTM26200 onwards. The chargeable profits of a company which comes within the charge to Corporation Tax in this way will include chargeable gains

  • accruing to it from the disposal of assets situated in the United Kingdom, where

    • For the tax years up to and including 2012/13 the same disposal by an individual who is not resident or not ordinarily resident in the United Kingdom would be chargeable to Capital Gains Tax.
    • For 2013/14 and subsequent tax years the same disposal by an individual who is not resident in the United Kingdom would be chargeable to Capital Gains Tax.

For further guidance, see CG42100+.