The commentary below considers the exposure of companies to tax on chargeable gains. For an overview of the taxation of chargeable gains generally, see C1.101.
Companies are subject to corporation tax on chargeable gains, rather than capital gains tax1.
The liability of companies to corporation tax on chargeable gains depends on the residence of the company.
Definition of company
For corporation tax purposes, the term 'company' means any body corporate or unincorporated association, but does not include a partnership, a co-ownership scheme, local authority or local authority association2.
The definition thus includes all companies (whether limited or unlimited), members' clubs, trade unions and professional bodies. This is discussed in more detail in D1.104.
Unit trusts are treated as companies for capital gains tax purposes but not for corporation tax purposes3. See C1.209.
Health service bodies are expressly exempt from both capital gains tax and corporation tax (as well as income tax)4. See D1.111.
Companies which are investment trusts or venture capital trusts (VCT) are exempt
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