Commentary

C1.607 Non-resident trusts

Capital gains tax
Capital gains tax | Commentary

C1.607 Non-resident trusts

Capital gains tax | Commentary

C1.607 Non-resident trusts

Where the trustees of a settlement are not resident, they are not charged to capital gains tax on trust gains, unless the gains arise from assets used in a UK trade (see C1.602), or they are subject to the capital gains tax charge that can arise on the disposal by non-residents of UK land, (the NRCGT rules, see C2.1130, and C2.1139). However, in defined circumstances trust gains may be attributed to the settlor or to UK resident beneficiaries and taxed as their chargeable gains.

For the detailed commentary on capital gains tax in respect

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