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HMRC internal manual

Capital Gains Manual

Non-resident companies: charge under TCGA92/S13: examples

In many cases a participator in a non-resident company will be a participator wholly or partly by reference to a holding of shares, and the calculation of that person’s interest and the interests of others will be relatively straightforward. Unless the context requires otherwise examples in this section, and in later sections relating to reliefs and adjustments, are in respect of participators whose interest in a company is by way of a holding of shares.