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HMRC internal manual

Capital Gains Manual

Non-resident companies: non-resident group: section 14: UK resident

As shown in Example 3 in CG57401 TCGA92/S14 applies even if the UK resident shareholder is not a company. Some taxpayers and tax advisers are uncertain about this because TCGA92/S171 includes the words `so far as relates to Corporation Tax on chargeable gains’. They suggest this means Section 14 can only apply if the TCGA92/S13 charge would be to Corporation Tax on chargeable gains. We do not take this restrictive view. This practice was published in Tax Bulletin, Issue 7, page 74.