The following Tax practice note provides comprehensive and up to date legal information covering:
This Practice Note is about the rules that can impose a charge to tax on UK persons holding interests in a non-UK resident company if that company disposes of an asset and makes a capital gain.
A non-UK resident company is normally chargeable to UK tax on gains only if:
it is carrying on a trade in the UK through a permanent establishment (PE), and the disposal is of assets situated in the UK that are used in, or for the purposes of, that trade or that PE, or
the disposal is of UK residential property or, for a disposal on or after 6 April 2019, of any interest in UK land (whether residential or non-residential) or of certain assets deriving their value from UK land
Similarly, a non-UK resident individual or trustee is normally chargeable to UK capital gains tax only if:
he or she carries on a trade or profession in the UK through a branch or agency, and the disposal is of assets situated in the UK that are used in, or for the purposes of, that trade or profession or that branch or agency, or
the disposal is of UK residential property or, for a disposal on or after 6 April 2019, of any interest in UK land (whether residential or non-residential) or of certain assets deriving
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