Robert Langston provides an outline of the rules in TCGA 1992 s 13 which can attribute the gains of overseas companies to UK shareholders
Outline of rules
Gains made by overseas companies can be subject to tax in the UK if they are attributed to shareholders or other participators under TCGA 1992 s 13. In most cases the participators will be the shareholders of the company but participators can also include loan creditors option holders and other persons who hold rights over the company.
The provisions of s 13 apply where:
