Related Commentary  Related HMRC Manuals

3A(1)  A gain accruing to a company on the disposal of an asset is taken to be “connected to avoidance” unless it is shown that neither–

(a)the disposal of the asset by the company, nor

(b)the acquisition or holding of the asset by the company,

formed part of a scheme or arrangements of which the main purpose, or one of the main purposes, was avoidance of liability to capital gains tax or corporation tax.

3A(2)  A gain is “connected to a foreign trade” if it accrues on the disposal of an asset used only–

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