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HMRC internal manual

Capital Gains Manual

Non-resident companies: capital dividends/distributions of gains

Before 28 November 1995, where a non-resident company realised a gain which was attributable to a UK resident shareholder and a distribution in respect of the gain was made within two years, then part or all of the gain was subject to exemption from Section 13 by virtue of subsection 5(a). This exemption was repealed by FA96/S174. A new tax credit relief was introduced to apply in similar circumstances, see CG57351+.