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HMRC internal manual

Capital Gains Manual

Residence and migration: companies: general

Broadly, the legislation aims to charge Corporation Tax on capital gains where there is an appropriate connection between a company realising a gain and the UK. The connection may be one of two types, either

  • the company is resident in the UK, or
  • although the company is not resident in the UK it carries on a trade in the UK through a permanent establishment.

This general scheme is affected in certain circumstances by the terms of double taxation treaties.

The following guidance tells you more about the effects of the following subjects on the liability to Corporation Tax on capital gains.

  • residence and the charge to Corporation Tax on capital gains, see CG42030+
  • trades carried on in the UK through a permanent establishment by companies that are not resident, see CG42100+
  • migration of companies, see CG42300+.

For information about assessing a UK resident company under TCGA92/S13 on the gains arising to non-resident companies in which the company is a direct or indirect participator, see CG57200+.