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HMRC internal manual

Capital Gains Manual

Non-resident companies: exemptions: participation level for gain to be attributable

TCGA92/S13(4) prevents any chargeable gain being treated as accruing to a participator if the aggregate amount of the company’s gain which would otherwise be attributed to them and to persons connected with them does not exceed:

for the years up to and including 2011-12 - 10 per cent of the company’s total gain;

for 2012-13 and subsequent years - 25 per cent of the company’s total gain.