C2.1145 Direct disposals of UK land by non-residents
This article covers the non-resident capital gains tax (NRCGT) regime that applies to disposals made on or after 6 April 2019. For the NRCGT regime that applied to disposals between 6 April 2015 and 5 April 2019, see C2.1130–C2.1138.
Direct disposals of UK land (whether residential or commercial) made by non-resident persons on or after 6 April 2019 are subject to UK tax.
Non-resident companies are chargeable to UK corporation tax on gains arising on such disposals. For other non-resident persons, any gain is subject to capital gains tax1.
For non-resident individuals making a direct disposal of residential property, the rate of tax on any gain is 18% for basic rate taxpayers and 28% for those with income above the basic rate income band. Where a non-resident individual makes a direct disposal of non-residential property, any