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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Recovery of CT from shareholders: gains made by the shareholder

TCGA92/S189 (5)

Section 189 has no bearing on the liability which may arise on a shareholder where the capital distribution received itself gives rise to a chargeable gain on that shareholder as it constitutes a disposal of an interest in shares in the company.