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A person is generally chargeable to Capital Gains Tax (“CGT�) on chargeable gains accruing in a tax year if they are resident in the UK, see CG10900P. There are certain exceptions to this rule provided by TCGA92, see CG10760.

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defines a person as including a body of persons corporate or unincorporate. Where it is appropriate the TCGA should be read as applying to companies as well as individuals.

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says that in any Act, unless the contrary intention appears,

a.ÌýÌýÌý words importing the masculine gender include the feminine;

b.ÌýÌýÌý words importing the feminine gender include the masculine;

c.ÌýÌýÌýÌý words in the singular include the plural and words in the plural include the singular.

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Chargeable persons include:

·ÌýÌýÌýÌýÌýÌýÌýÌý individuals, see CG20220C

·ÌýÌýÌýÌýÌýÌýÌýÌý partners in a business partnership, see CG27000C

·ÌýÌýÌýÌýÌýÌýÌýÌý trustees of settlement trusts, see CG33000C

·ÌýÌýÌýÌýÌýÌýÌýÌý personal representatives of deceased persons, see CG30500P

·ÌýÌýÌýÌýÌýÌýÌýÌý companies, see CG40200C.

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There are special provisions for attributing:

·ÌýÌýÌýÌýÌýÌýÌýÌý The gains accruing to a closely controlled non-resident company to UK resident members of that company, see or (for disposals before 6 April 2019) andÌýCG13500+.

·ÌýÌýÌýÌýÌýÌýÌýÌý The gains accruing to the trustees of non-resident settlements to a UK domiciled and resident settlor, see andÌýCG38430, or UK resident beneficiaries who receive capital payments from the trustees, see andÌýCG38570C.

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Beneficial owner

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For capital gains purposes, the person chargeable is normally the ‘beneficial� owner of the asset which has been disposed of. Often, the beneficial owner of the asset is also the legal owner of the asset but this is not always the case.

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Any actions by

·ÌýÌýÌýÌýÌýÌýÌýÌý nominees, see andÌýCG34320+,

·ÌýÌýÌýÌýÌýÌýÌýÌý bare trustees (that is, where the person is absolutely entitled to property held by trustees), see andÌýCG34300+,

·ÌýÌýÌýÌýÌýÌýÌýÌý receivers, liquidators or trustees in bankruptcy, see (s8(6) for disposals before 6 April 2019), ,ÌýCG20500ÌýandÌýCG40400+Ìý

·ÌýÌýÌýÌýÌýÌýÌýÌý mortgages or charge holders or any other persons entitled to the asset by way of security, see andÌýCG12706,

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are attributed to the beneficial owner so that any gain or loss accruing on an actual disposal of the asset by the nominee etc. accrues to the beneficial owner (and not the nominee). The transfer of legal ownership between a nominee and the beneficial owner does not constitute a disposal for the purposes of TCGA92.