Taxation of Chargeable Gains Act 1992 section 275C

Location of assets: interests of co-owners

Section 275C determines where a co-owner's interest in an asset is located for capital gains tax purposes, and in particular whether that interest is situated in the United Kingdom.

• A co-owner's interest in an asset is treated as being located in the same place as the asset itself.
• The location of the asset is determined as though the co-owner in question were the sole owner of the entire asset.
• The rule applies regardless of whether the asset is held jointly or in common, and regardless of whether co-owners hold equal or unequal shares.
• Partnership assets fall within the scope of this provision, since each partner holds a co-ownership interest in the partnership's assets.