Non-resident CGT—summary [Archived]
Produced in partnership with Alison Cartin of Bryan Cave Leighton Paisner
Non-resident CGT—summary [Archived]

The following Private Client practice note Produced in partnership with Alison Cartin of Bryan Cave Leighton Paisner 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...

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 It has been archived and is not maintained.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 (ie using

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