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Home / Simons-Taxes /Capital gains tax /Part C1 Capital gains /Division C1.6 Foreign element of chargeable gains /Foreign element—generally / C1.604A Location ('situs') of assets for the purposes of the taxation of chargeable gains—intangible assets
Commentary

C1.604A Location ('situs') of assets for the purposes of the taxation of chargeable gains—intangible assets

Capital gains tax

Individuals, trustees and personal representatives are subject to capital gains tax on chargeable gains. Companies are subject to corporation tax on chargeable gains. The extent to which gains are taxable and losses are allowable in the UK depends on the residence status, and potentially the domicile status of the person and the location of the asset.

The rules that apply to determine the location of assets for the purposes of the taxation of chargeable gains and why these rules are important are discussed in C1.604. For details of the impact of the residence and domicile status of the person on the taxation of chargeable gains, see C1.102.

The commentary below discusses the statutory rules that apply to determine the location of certain intangible assets for the purposes of the taxation of chargeable gains.

Note that different rules apply to determine the situs of assets for inheritance tax purposes. For details, see Division I9.4.

When considering whether or not an asset is located in the UK in the

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Web page updated on 17 Mar 2025 13:41