Commentary

D6.613 Capital treatment—vendor residence status

Corporate tax
Corporate tax | Commentary

D6.613 Capital treatment—vendor residence status

Corporate tax | Commentary

D6.613 Capital treatment—vendor residence status

The vendor (and his nominee, if any) must be resident (and for shares acquired before 6 April 2013, ordinarily resident) in the UK in the tax year of sale1.

Vendor trustees will be considered resident (and before 6 April 2013, ordinarily resident) in the UK at any time when either:

  1.  

    (a)     all the trustees are resident in the UK; or

  2.  

    (b)     at least one trustee is resident in the UK and one is not, and the settlor was resident (and for settlements made before 6 April 2013, ordinarily resident) or domiciled in the UK when

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial