[3 Gains attributed to UK resident individuals etc]
Taxation of Chargeable Gains Act 1992 (1992 c 12) | Legislation

[Chapter 3
Attribution of Gains of Non-UK Resident Close Companies]

[Gains of non-UK resident companies not otherwise chargeable]

[3  Gains attributed to UK resident individuals etc]

[(1)     This section applies if—

(a)     a chargeable gain accrues at any time to a non-UK resident close company,

(b)     the gain is connected to avoidance (see section 3A),

(c)     the gain is not connected to a foreign trade or other economically significant foreign activities (see section 3A), and

(d)     apart from this section, some or all of the gain would not be chargeable to corporation tax on the company.

(2)     So much of the gain as would not otherwise be so chargeable is apportioned among participators, or indirect participators, in the company—

(a)     who are resident in the United

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