Non-resident CGT—summary [Archived]
Produced in partnership with Alison Cartin of Taylor Wessing LLP

The following Private Client practice note produced in partnership with Alison Cartin of Taylor Wessing LLP provides comprehensive and up to date legal information covering:

  • Non-resident CGT—summary [Archived]
  • Scope of non-resident CGT
  • What is not subject to NRCGT?
  • What is a diversely-held company?
  • Partnerships
  • Calculating NRCGT
  • Rate of NRCGT and annual exempt amount
  • Calculating the gain subject to NRCGT
  • Disposal also subject to ATED-related CGT
  • Non-residential or mixed use
  • More...

Non-resident CGT—summary [Archived]

ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied to certain non-UK resident persons when they disposed of UK residential property on or after 6 April 2015 and before 6 April 2019. It has been archived and is not maintained.

Changes to the taxation of gains made by non-UK residents on UK immovable property took effect from 6 April 2019. These changes are included in section 13 and Schedule 1, Part 1 to the Finance Act 2019. For more details, see Practice Note: Non-residents and tax on chargeable gains from 6 April 2019—gains and UK immovable property.

For disposals on or after 6 April 2015 and before 6 April 2019, an NRCGT charge applies to non-UK resident individuals, trustees, closely-held funds and companies on the disposal of UK residential property. NRCGT applies to disposals of UK residential property of any value including property which is let as part of a property rental business. It also applies to the disposal of a right to acquire UK residential property ‘off-plan’.

NRCGT only applies to gains which accrue post 5 April 2015. This is the default position but in certain circumstances the person disposing of the property can elect for a straight-line time apportionment of the whole gain over their period of ownership or a retrospective basis of computation

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