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HMRC internal manual

Capital Gains Manual

Non-resident companies: exemptions: foreign currency and currency bank accounts: TCGA92/S13(5)(c)

TCGA92/S13 does not apply to gains arising on the disposal of

  • any foreign currency held by a non-resident company
  • credit balances on a foreign currency bank account

provided that the funds are used for the purposes of a trade carried on by a non-resident company wholly outside the UK. The purpose of the exemption and the exemption for trading assets, see CG57310, is to prevent TCGA92/S13 applying to a foreign company’s trading activities. You should not enquire about foreign currency operations unless there is evidence the foreign currency was not held for trading purposes and the amounts involved are likely to be material.