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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 / C1.606 Gains and losses of non-resident closely held companies attributed to UK resident participators
Commentary

C1.606 Gains and losses of non-resident closely held companies attributed to UK resident participators

Capital gains tax

The liability of companies to UK corporation tax in respect of disposals of chargeable assets depends on the company's residence status. For the meaning of residence for companies, see D4.103.

Non-resident companies are generally chargeable to UK corporation tax in respect of gains and losses accruing from the disposal of certain UK assets only1.

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