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Historically, only UK resident individuals and entities, together with temporary non-UK resident individuals and those operating via a UK permanent establishment, branch or agency, have been subject to UK capital gains tax (CGT) whilst non-UK residents have not. However, this was widened from 6 April 2013 to include disposals of UK dwellings owned by non-resident companies, partnerships and collective investment schemes where the dwelling was subject to the annual tax on enveloped dwellings (ATED) charge. For more on the ATED charge and the ATED-related CGT charge, see the Overview of the ATED regime guidance note.

From 6 April 2015, the CGT regime was extended to non-UK residents disposing of UK residential property. This is known as the non-resident capital gains tax (NRCGT) 2015 regime (also known as FA 2015 NRCGT or FA15 NRCGT).

The NRCGT 2015 regime was repealed and replaced by a new NRCGT regime with effect from 6 April 2019. This extended NRCGT to cover disposals of non-residential and mixed UK property and indirect disposals of UK land (eg