CG57395 - Non-resident companies: tax adjustment and reliefs: non-resident trustees
TCGA92/S13 (10)*
TCGA92/S13 (10) allows the gains of non-resident companies to be apportioned to non-resident trustees. A non-resident trust is not normally liable to UK Capital Gains Tax. But there are provisions for charging the gains of the trust on UK resident settlors and beneficiaries, see CG38200+. These provisions also apply to a charge under gains falling within TCGA92/S13.
* TCGA92/S13 was re-written for disposals from 6th of April 2019 see CG10150.