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HMRC internal manual

Capital Gains Manual

Administration: introduction: company acting in fiduciary capacity

ICTA88/S8 (2)

Chargeable gains which accrue to a company in a fiduciary or representative capacityare excluded from the charge to Corporation Tax, see CTM01120. Such gains are, however,chargeable to Capital Gains Tax on the company in accordance with the normal rules fortrustees, see CG35200+. This will happen, for example, where a trustee company holds theinvestments of an unapproved superannuation fund and realises chargeable gains on thedisposal of any of those investments.