In determining whether UK tax is computed by reference to the same gain on which the foreign tax is charged, there is no necessity that the respective tax liabilities should arise at the same time or that they should be charged on the same person. Thus, the same gain is regarded as taxed both overseas and in the UK where, for example:

overseas tax is payable on a no gains/no loss disposal within a UK group of companies and liability to UK tax arises on the subsequent disposal of the asset taking in the uplift in value to the date of the first disposal under TCGA92/S171

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