Personal Tax

Disposal of a main home by a non-resident individual under non-resident capital gains tax (NRCGT)

Produced by Tolley
  • 26 Apr 2022 10:40

The following Personal Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Disposal of a main home by a non-resident individual under non-resident capital gains tax (NRCGT)
  • Background reading on PPR relief and NRCGT
  • Non-qualifying tax years
  • What is a non-qualifying tax year?
  • What is the day count test?
  • Nominating the house as main residence in a non-qualifying year under NRCGT
  • Section 222A nomination
  • Periods of absence deemed to be periods of occupation
  • Periods of absence straddling 6 April 2015
  • Period of ownership under NRCGT
  • More...

Disposal of a main home by a non-resident individual under non-resident capital gains tax (NRCGT)

The non-resident capital gain tax (NRCGT) regime was first implemented in 6 April 2015 to apply to non-UK residents disposing of UK residential property and is referred to as the NRCGT 2015 regime below. It was extended with changes to the regime from 6 April 2019, referred to as the NRCGT 2019 regime below.

The changes effectively rewrote the provisions of the original NRCGT regime and extended it to include transactions in land generally. This includes the disposal of non-residential UK property and indirect disposals of UK property with effect from 6 April 2019. The result is that all disposals of interests in UK land (including buildings) by non-residents are now within the scope of NRCGT.

For detailed commentary on the other aspects of NRCGT disposals, see the guidance notes listed below. Many of these guidance notes also look at aspects affecting the disposal of a main residence. However, the purpose of this guidance note is to draw out those elements of the NRCGT regime that apply specifically to the disposal of a dwelling house that has at some point been a main home. It looks at the application of principal private residence relief (PPR relief, also known as only or main residence relief or private residence relief).

Background reading on PPR relief and NRCGT

Topic summaryGuidance note
PPR relief is discussed in detail in several guidance notes. This guidance note contains an

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