CG42000 - Residence and migration: companies: general

Broadly, the legislation aims to charge Corporation Tax on capital gains where there is an appropriate connection between a company realising a gain and the UK. »Ê¹ÚÌåÓýapp connection may be one of two types, either

  • the company is resident in the UK, or
  • although the company is not resident in the UK it carries on a trade in the UK through a permanent establishment.

This general scheme is affected in certain circumstances by the terms of double taxation treaties.

»Ê¹ÚÌåÓýapp following guidance tells you more about the effects of the following subjects on the liability to Corporation Tax on capital gains.

  • residence and the charge to Corporation Tax on capital gains, see CG42030+
  • trades carried on in the UK through a permanent establishment by companies that are not resident, see CG42100+
  • migration of companies, see CG42300+.

For information about assessing a UK resident company under TCGA92/S13 on the gains arising to non-resident companies in which the company is a direct or indirect participator, see CG57200+.