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HMRC internal manual

International Manual

Controlled Foreign Companies: legislation - introduction and outline: Relief against double charge: subsequent disposal

A company which has suffered a Chapter IV charge may dispose of some or all of its shareholding in the controlled foreign company which gave rise to the charge. If it does so, the Chapter IV tax (or a proportionate part of it) is deductible in computing the chargeable gains on the disposal of the shares, provided that the tax has not been relieved by set off as described in INTM256230 to INTM256320. Details of the Capital Gains Tax relief are found at INTM256220.