Non resident client sold goodwill of UK partnership to a UK Limited company. Is this taxable in the UK?
Angel
Replies (2)
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Nothing has changed
Yes, generally speaking non-residents are not liable to CGT by reason of our domestic law but there has been ,for years, one exception. If the NR was conducting a trade through a UK branch or agency in the year assets used in that trade were sold, then any realised gains are liable unless (and this would be unusual) the DTA with the country of residence states that only the latter can tax.
Non Resident
I always thought that CGT was not taxable on non residents. Has something changed recently to affect this?