HC Deb 06 April 1965 vol 710 c246
The Chancellor of the Exchequer (Mr. James Callaghan)

It has been suggested that a double charge will arise, which ought to be relieved, if a company is taxed on its capital gains and its shareholders are also taxed on the gains which they make on disposal of their shares. I regret that I cannot accept this view. The capital gains of the company and of the shareholders are two separate things, just as under the Corporation Tax structure the profits of the company and the dividend of the shareholder are two separate things. There is no more reason to give credit in the one case than in the other.