Taxation of Chargeable Gains Act 1992 section 14G

Section 14F: divided companies

Section 14G provides supplementary rules for applying the temporary non-residence provisions in section 14F where a company has been divided into two or more successor companies during the relevant period.

• Where a company is divided into successor companies during the period of temporary non-residence, section 14F still applies to gains and losses that would otherwise escape UK taxation.
• The section ensures that chargeable gains or losses attributed to the original company are properly allocated to the appropriate successor company or companies.
• This prevents taxpayers from using corporate restructuring or demerger arrangements to circumvent the anti-avoidance rules that apply when individuals return to the UK after a period of temporary non-residence.
• The provisions were introduced by Finance Act 2019 as part of a broader package of reforms to the temporary non-residence rules affecting chargeable gains.

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