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. Whether gains or losses are within the scope of capital gains tax or corporation tax depends on the residence status of the person and, in the case of individuals, their domicile status. See C1.102.
The commentary below considers relief available for delayed remittances. This relief may also be known as relief for unremittable gains, unremittable foreign gains or unremittable overseas gains.
For the similar relief that applies to unremittable income, see E1.607 (income tax) and D1.303 (corporation tax)1. Special rules apply in relation to controlled foreign companies, see D4.421.
Despite the name of the relief, it should not be confused with the remittance basis of taxation for individuals; relief for delayed remittances applies to persons who are taxable
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