62 Attribution of gains to members of non-resident companies

Capital gains

62  Attribution of gains to members of non-resident companies

(1)     TCGA 1992 is amended as follows.

(2)     In subsection (4) of section 13 (members to whom rule for attributing gains to members of non-resident companies does not apply), for “one tenth” substitute “one quarter”.

(3)     In subsection (5) of that section (cases where rule for attributing gains to members of non-resident companies does not apply), after the “or” at the end of paragraph (b) insert—

“(ca)     a chargeable gain accruing on the disposal of an asset used, and used only, for the purposes of economically significant activities carried on by the company wholly or mainly outside the United Kingdom, or

(cb)     a chargeable gain accruing to the company on a disposal of an asset where it is shown that neither—

(i)     the disposal of the asset by the company, nor

(ii)     the acquisition or holding of the asset by the company,

formed part of a scheme or arrangements

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