The following Tax Q&A provides comprehensive and up to date legal information covering:
When working out any gain falling within the non-resident close company apportionment rules (sections 3–3G of the Taxation of Chargeable Gains Act 1992 (TCGA 1992)), it may be assumed that the company is UK-resident and chargeable to corporation tax: see the new TCGA 1992, s 3G(3). This was true under the previous rules. Therefore, if the non-resident close company owns UK land which it disposes of at a gain, any gain to be apportioned is the one which would arise if that company had been UK-resident at all material times. On this assumption, rebasing as at 6 April 2019 should be irrelevant: the close company apportionment rules have not changed in substance at 6 April 2019 and this gain would have been taxable on participators by apportionme
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