When is a UK shareholder subject to tax on a gain realised by a non-resident company? Jackie Wheaton (Moore Stephens) reviews the key points.
Question
A client company is incorporated in the British Virgin Islands (BVI) and is regarded as non-UK resident for tax purposes. It holds shares in a UK company and has received an offer to sell these shares to a third party. All of the shareholders of the BVI company are UK resident and domiciled. My client wonders whether the shareholders will be subject to UK tax in respect of the gain realised by the BVI company.
Answer
Non-resident companies are generally chargeable only on gains accruing from the disposal of trading assets situated in the UK although a capital gains tax charge can arise on the disposal by non-residents of UK residential property falling within the annual...
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When is a UK shareholder subject to tax on a gain realised by a non-resident company? Jackie Wheaton (Moore Stephens) reviews the key points.
Question
A client company is incorporated in the British Virgin Islands (BVI) and is regarded as non-UK resident for tax purposes. It holds shares in a UK company and has received an offer to sell these shares to a third party. All of the shareholders of the BVI company are UK resident and domiciled. My client wonders whether the shareholders will be subject to UK tax in respect of the gain realised by the BVI company.
Answer
Non-resident companies are generally chargeable only on gains accruing from the disposal of trading assets situated in the UK although a capital gains tax charge can arise on the disposal by non-residents of UK residential property falling within the annual...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
