Taxation of Chargeable Gains Act 1992 section 2F

Interaction of capital gains tax and corporation tax

Section 2F establishes that capital gains tax and corporation tax should be treated as a single tax for the purposes of the Taxation of Chargeable Gains Act 1992, ensuring consistent treatment across individuals and companies.

• The operation of the Act is not affected by the fact that capital gains tax (CGT) and corporation tax (CT) are legally distinct taxes.
• The Act applies to CGT and CT on chargeable gains as though they were one and the same tax, provided this is consistent with the Corporation Tax Acts.
• Where a transaction involves both an individual and a company, the same principles apply — to the individual for CGT purposes and to the company for CT purposes.
• This unified treatment ensures that equivalent transactions are not treated differently simply because one party is an individual subject to CGT and the other is a company subject to CT.