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HMRC internal manual

Capital Gains Manual

Non-resident companies: disposal of interest/shares by UK resident

This example illustrates the deduction under TCGA92/S13(7) if the taxpayer sells shares in a non-resident company whose gains have been apportioned under TCGA92/S13.


  • June 2008 a taxpayer buys £500 out of the £750 issued shares in X Ltd, a non- resident close company, at a cost of £100,000.
  • March 2009 X Ltd realises a gain of £6,000. 500/750 x £6,000 = £4,000 is apportioned to the taxpayer. The amount is included in the 2008-09 Capital Gains Tax assessment. The taxpayer is liable at 18 per cent and tax of £720 is due.
  • August 2010 the taxpayer sells the shares for £130,000.

Chargeable Gain

  Disposal proceeds   130,000
less Cost 100,000  
less Section 13(7) deduction 720 100,720
  Chargeable gain   29,280
less Annual exempt amount (say)   10,200
  Amount chargeable   19,080

NOTE. If a taxpayer is within the charge to Capital Gains Tax, neither indexation allowance nor taper relief apply to disposals of assets on or after 6 April 2008. Previously indexation allowance had been frozen at April 1998. For indexation allowance see CG17207+ and for taper relief see CG17895+.