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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Non-resident companies: non-resident group


A TCGA92/S13 charge could arise on the disposal of an asset by a non-resident company to another company under the control of the same shareholders or participators. TCGA92/S14 prevents this if the transfer is between members of a non-resident group of companies, see CG57401. It does this by applying some of the general Capital Gains Tax rules for groups to non-resident groups for the purposes of calculating the Section 13 charge.