A shareholder that is connected with a UK-resident company may be charged to tax in the name of the company in respect of unpaid tax on chargeable gains to the extent that such gains have been distributed to them, as set out below.

A person so chargeable must be ‘connected’ with the distributing company within the terms of the chargeable gains legislation (TCGA 1992, s. 189(1); for the meaning of ‘connected’, see ¶503-750).

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