One of our clients is looking at selling the company and some of the minority shareholders are non-resident.
CG2550 mentions that if a non-resident carries on a trade in the UK through a branch or agency then they will be within the charge to CGT. However, the charge does not apply to any person exempt from income tax on the profits of the branch or agency because of Double Taxation agreements.
As most of the minority shareholders would not have been liable to income tax on the dividends, woudl you consider that they would not be liable to UK CGT on the shares.
Any answers appreciated.