CG50243 - Definitions: tax analysis: - situation of assets

Although the DR itself may be issued outside the UK, you should not accept any suggestion that a disposal of shares in a UK registered company held in DR form by a non-domiciled person should give rise to chargeable gains only on a remittance basis, see CG25300+. It is to be expected that the great majority, or all, of any consideration on such a disposal will be attributable to the disposal of the beneficial interest in the shares themselves. The shares are, under TCGA92/S275 (e), assets located in the UK, see CG12440, so the remittance basis will not apply.