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HMRC internal manual

Capital Gains Manual

Non-resident companies: exemptions: UK permanent establishment: TCGA92/S13(5)(d)

TCGA92/S13 does not apply to assets which are used for the purposes of a trade carried on in the UK through a permanent establishment. Any gain on the disposal of these assets is already taxed under TCGA92/S10B. The exemption in TCGA92/S13 (5)(d) applies to all gains caught by TCGA92/S10B including deemed disposals when the trade ceases or when the assets are transferred outside the UK. For guidance on TCGA92/S10B see CG42100+.