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HMRC internal manual

Capital Gains Manual

Non-resident companies: exemptions: assets used for trading carried on outside the UK

TCGA92/S13(5)(b) disapplies TCGA92/S13 for gains on the disposal of all assets used only for the purposes of a trade carried on by the non-resident company either wholly

* outside the UK, or
* in a part of a trade and that part is carried on wholly outside the UK.

Therefore gains on all such assets (including intangible assets such as goodwill) will not be treated as chargeable gains accruing to participators.

For gains on disposals from 6 April 2012, the definition of trade assets for the purposes of TCGA93/S13 was extended and may also include assets such as accommodation or an interest or right in accommodation, which is situated outside the UK where the accommodation has been furnished holiday accommodation. See CG57313.