Revenue Note for Guidance
By virtue of the application, with any necessary modifications, of sections 1034 and 1035 for the purposes of capital gains tax, a non-resident person may be assessed and charged to capital gains tax in the name of any trustee, guardian, agent, receiver or manager in the same manner as if the non-resident was a resident person, notwithstanding the fact that the trustee, guardian, etc may not be in receipt of the gains liable to tax. Similarly, a non-resident person is assessable and chargeable to capital gains tax in respect of chargeable gains arising, directly or indirectly, through or from any factorship, agency, receivership, branch or management and is assessable and chargeable in the name of the factor, agent, receiver, branch or manager.
Relevant Date: Finance Act 2019