[CG38405] Charges in respect of non-resident settlements
Charges on the trustees
Trustees of non-resident settlements are not normally liable to Capital Gains Tax because they are not resident in the UK. Two exceptions are:
(1)If they carry on a trade in the UK through a branch or agency, TCGA92/S10*. This is uncommon. The guidance on section 10 in CG25500+ for individuals can be applied to trustees.
(2)If the disposal is of UK property. From 6 April 2015 to 5 April 2019 a charge could arise on disposals of interests in UK residential property. The scope of charge was widened from 6 April 2019. See the guidance from CG73700.