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HMRC internal manual

Capital Gains Manual

Non-resident companies: TCGA92/S13: liaison with other offices

As you are required to make an apportionment that is just and reasonable by reference to the interests of all of the participators, you will need to liaise with other officers dealing with participators in the non-resident company. In appropriate cases you should agree that a single nominated officer co-ordinate the progress of the enquiries, or conduct the enquiry in respect of some or all of the participators, for example, where all of the participators are represented by the same agent. In any case where a non-resident trust is involved Specialist PT (Residence), see CG57395, should be notified and will normally act as the office co-ordinating HMRC’s enquiries.

It will usually be appropriate to ensure that all appeals relating to the extent of the interests of participators with regard to a particular gain are heard at the same hearing, see AH1795.