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STOP PRESS: The remittance basis is to be abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in Finance Bill 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

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