JOHN TALLON QC assesses the CGT measures proposed in the 2005 Budget.
THE GENERAL RULE is that liability to UK CGT on chargeable gains accruing on the disposal of an asset only attaches to taxpayers who are either resident or ordinarily resident in the UK in the year of assessment in which the disposal is made ( TCGA 1992, s 2(1) ). That general rule is subject 'to any exceptions provided' by the TCGA.
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