If the UK domestic law says no CGT applies yet the relevant double tax treaty says Capital Gains Tax should apply.
Is it just a case of completing a UK tax return or is there any other formality to follow.
Thanks
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Why do you think a DTA can impose a CGT liability where none exists in domestic legislation?
No CGT
That is correct TaxGuru
Then there is no UK tax as s.2(1) is still rock solid! The DTA override is irrelevant.