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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Non-resident companies: tax adjustment and reliefs: non-resident trustees

TCGA92/S13 (10)

TCGA92/S13 (10) allows the gains of non-resident companies to be apportioned to non-resident trustees. A non-resident trust is not normally liable to UK Capital Gains Tax. But there are provisions for charging the gains of the trust on UK resident settlors and beneficiaries, see CG38200+. These provisions also apply to a charge under gains falling within TCGA92/S13.

All cases involving the assessment of non-resident trusts are dealt with by Specialist PT Trusts & Estates. Any information about TCGA92/S13 gains attributable to non-resident trusts should be sent to that office. See CG38400+.