Commentary

C1.606 Non-resident closely held companies

Capital gains tax
Capital gains tax | Commentary

C1.606 Non-resident closely held companies

Capital gains tax | Commentary

C1.606 Non-resident closely held companies

Non-resident companies are generally chargeable only on gains accruing from the disposal of trading assets situated in the UK1 (but see C1.602 for the exception applying to overseas life insurance companies), and on disposals of certain interests in UK land (see C1.601). However, where the non-resident company satisfies all the conditions for a close company (see D3.102) apart from that as to residence in the UK, its participators2 who are resident in the UK may (subject to certain specific exclusions) be charged to CGT in respect of its gains (calculated

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