Paragraph 96

In section 13 (attribution of gains to members of non-resident companies), after subsection (3) insert—

“(3A)

Subsection (2) does not apply in the case of a participator who is an individual if—

(a)

the tax year in which the chargeable gain accrues to the company is a split year as respects the participator, and

(b)

the chargeable gain accrues to the company in the overseas part of that year.”