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Disposal by a non-resident company


A client company is incorporated in the British Virgin Islands (BVI) and is regarded as non-UK resident for tax purposes. It holds shares in a UK company and has received an offer to sell these shares to a third party. All of the shareholders of the BVI company are UK resident and domiciled. My client wonders whether the shareholders will be subject to UK tax in respect of the gain realised by the BVI company.


Non-resident companies are generally chargeable only on gains accruing from the disposal of trading assets situated in the UK although a capital gains tax charge can arise on the disposal by non-residents of UK residential property falling within the annual tax on enveloped dwellings (ATED) or non-resident CGT (NRCGT) regime. In the absence of specific legislation it would therefore be possible for a...

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