Capital gains

Capital gains guidance:

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...

Practice Note

This Practice Note sets out how the capital allowances rules interact with the rules relating to: • capital gains tax, including corporation tax on chargeable gains (CGT)...

Practice Note

Companies that are members of the same capital gains group may transfer assets between themselves free of corporation tax on chargeable gains (CGT), see Practice Note:...

Practice Note

The capital gains degrouping rules apply where, broadly speaking, a company leaves a group holding an asset that was transferred to it by another member of...

Practice Note

The capital gains legislation includes specific provisions for persons who are connected with one another. These provisions can be divided into two broad groups: • rules...

Practice Note

ARCHIVED: This Practice Note has been archived and is not maintained. The annual tax on enveloped dwellings (ATED) was introduced in Finance Act 2013 (FA 2013) as part of...

Practice Note

This Practice Note is about the rules for establishing whether companies are within the same group for the purposes of corporation tax on chargeable gains. In many ways a...

Practice Note

FORTHCOMING CHANGE relating to transfers within an EU group: Finance Bill 2020 is expected to contain provisions permitting companies to pay tax in instalments in...

Practice Note

For a taxable capital gain to arise, there has to be a disposal, or a deemed disposal, of an asset. The taxpayer will need to establish when the disposal took place. This...

Practice Note

FORTHCOMING CHANGE relating to a corporate capital loss restriction: Finance Bill 2019–20 will introduce a corporate capital loss restriction (CCLR), limiting companies’...

Practice Note

Entrepreneurs' relief is a capital gains tax (CGT) relief designed to encourage individuals to set up and expand their own businesses. Provided that the conditions are...

Practice Note

Investors’ relief is a capital gains tax (CGT) relief introduced by Finance Act 2016, designed for individuals who invest in unquoted trading companies, without being...

Practice Note

FORTHCOMING CHANGE: As originally announced at Budget 2018, the government ran a consultation between 1 April and 1 June 2019 on proposals to curtail capital gains tax...

Practice Note

FORTHCOMING CHANGE: As originally announced at Budget 2018, the government ran a consultation between 1 April and 1 June 2019 on proposals to curtail capital gains tax...

Practice Note

[Team Leader] [insert HMRC address] [insert date] Application for clearances in advance under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains Act 1992][ and...

Precedents

A demerger means the separation of a company’s business into two or more parts, typically carried on by successor companies under the same ownership as the original...

Practice Note

The rules dealing with depreciatory transactions and dividend stripping are anti-avoidance provisions. They target the artificial transfer of value out of a company by...

Practice Note

The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...

Practice Note

The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...

Practice Note

The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...

Practice Note

The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...

Practice Note

The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...

Practice Note

HM Revenue and Customs [insert address] [insert date] Election under section 171A(4) of the Taxation of Chargeable Gains Act 1992 This election is made jointly by [insert...

Precedents

Although the Taxation of Chargeable Gains Act 1992 (TCGA 1992) does not set out how to calculate a capital gain (referred to in the legislation as a chargeable gain), the...

Practice Note

When a sole trader (or an individual running a business as a partner in a partnership) decides to incorporate that business, he transfers the assets of that business to a...

Practice Note

ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied to certain non-UK resident persons when they disposed of...

Practice Note

FORTHCOMING CHANGE relating to collective investment schemes: HMRC consulted from 17 September 2019 to 25 October 2019 on draft regulations that amend the rules for...

Practice Note

This Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general partnerships, limited liability partnerships (LLPs) and...

Practice Note

FORTHCOMING CHANGE relating to a corporate capital loss restriction: Finance Bill 2019–20 will introduce a corporate capital loss restriction (CCLR), limiting companies’...

Practice Note

FORTHCOMING CHANGE relating to a corporate capital loss restriction: Finance Bill 2019–20 will introduce a corporate capital loss restriction (CCLR), limiting companies’...

Practice Note