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HMRC internal manual

Double Taxation Relief Manual

Non-residents: UK income: Special roll-over provisions

TCGA92/S159 which also dates from 1989 prevents roll-over of gains on branch assets against assets on which gains would not be within the United Kingdom’s charge to tax because, for example, they are situated abroad. Until 30 November 1993 it was necessary to have a corresponding provision in TCGA92/S160 to prevent roll-over of gains on assets of a permanent establishment of a treaty non-resident company (see CT3394) against assets outside our charge.