Capital gains realized by a company is taxed at the same rate as trading income. Capital losses may reduce capital gains but not trading income. Certain types of profits and losses – those from debt and intellectual property – are always treated as income under special regimes which reflect the accounting treatment of those types of assets.
Capital gains realized by non-resident companies are not taxed in the UK, even if they arise on the disposal of UK assets, unless:
- The asset is used for the purpose of a trade carried on by the company through a UK permanent establishment, or
- The asset comprises an interest in UK residential property which is subject to non-resident capital gains tax (NRCGT) or ATED CGT
From April 2019, non-resident companies will be liable to UK tax on gains realized on the direct or indirect disposal of UK real estate generally, subject to certain exemptions, and special rules for collective investment vehicles.