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For a gain or loss to be within the scope of tax on chargeable gains, there must be a chargeable disposal of a chargeable asset by a chargeable person. See C1.102–C1.104.

Individuals, trustees and personal representatives are subject to capital gains tax on chargeable gains. Companies are subject to corporation tax on chargeable gains. See C1.102 for a summary of the territorial scope of UK tax on chargeable gains.

This article discusses liability of a UK non-resident to UK tax where that person carries on a trade through a UK branch, agency or permanent establishment. The rules for capital gains tax, which apply to non-resident individuals, trusts and personal representatives, are found in TCGA 1992, s 1B. The rules for corporation tax, which apply to companies, are found in TCGA 1992, s 2C. Note that the legislation was rewritten with effect from 6 April 2019 when TCGA 1992, Pt 1 was replaced, but this was not intended to change the effect of the provisions.

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