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Practice guide: Attribution of gains of overseas companies

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Gains made by overseas companies can be attributed to UK shareholders, regardless of whether the shareholder is an individual or a company. Corporation tax or CGT can therefore arise even if the gain is not distributed to the shareholder. Certain assets are excluded from the rules and reliefs are available for intra-group transfers. Furthermore, the substantial shareholding exemption may apply, and relief may be available under a double tax treaty.

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