Commentary

C2.1134 Computation of non-resident CGT (NRCGT) gains and losses involving relevant high value disposals

Capital gains tax
Capital gains tax | Commentary

C2.1134 Computation of non-resident CGT (NRCGT) gains and losses involving relevant high value disposals

Capital gains tax | Commentary

C2.1134 Computation of non-resident CGT (NRCGT) gains and losses involving relevant high value disposals

The rules in C2.1130–C2.1138 apply to disposals made prior to 6 April 2019. For disposals made on or after 6 April 2019, see C2.1139–C2.1173. Transitional rules apply to unused losses existing at 6 April 2019 that have accrued on disposals made prior to that date. See C2.1142 for further details.

Where a non-resident CGT disposal is, or involves, one or more relevant high value disposals (see C2.1127) the NRCGT gain or loss is the sum of the NRCGT gains or losses accruing on each relevant high value disposal calculated as outlined in this article1. Where part only of the land disposed of is a relevant high value disposal so that the gain that accrues is wholly or in part chargeable to ATED-related CGT (see C2.1125), the remaining part of the land is treated for these purposes in the same way as if it formed part of the relevant high value disposal2.

The FA 2015 NRCGT regime applies only to disposals of residential property and only where the disposal is made between 6 April 2015 and 5 April 2019. From 6 April 2019, an extended NRCGT regime applies to all types of UK land, including commercial property (referred to as the FA 2019 NRCGT regime). See C2.1139.

Assets held on 5 April 2015, no election to compute gains or losses on the basis of the position over the whole period of ownership, and no additional rebasing in 2016 required

Where

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