Policy paper

Capital gains: preventing protected cell company avoidance 

This tax information and impact note affects UK resident individuals, trustees and companies who hold assets through a non-UK resident protected cell company. 

• From: HM Revenue & Customs
• Published: 28 October 2026

Documents

Capital gains — preventing protected cell company avoidance 

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Draft legislation

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Explanatory note

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Details

This measure changes the capital gains rules that apply to gains made by non-resident close companies that are attributed to UK resident individuals, trusts and companies.

This measure takes effect from 28 October 2026.