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Non-resident capital gains tax on disposals of interests in UK land

Under the non-resident capital gains tax (NRCGT) regime, non-residents are subject to UK capital gains tax on the following disposals:

1. •

   direct disposals of an interest in UK land (eg the non-resident disposes of UK land that they own)

2. •

   indirect disposals of an interest in UK land, ie disposals of an asset that derive at least 75% of their value from UK land in which the taxpayer has a substantial indirect interest in the land (eg the non-resident disposes of shares in a company that owns UK land)

TCGA 1992, ss 1A(3)(b), (c), 2B(4)–(6)

The NRCGT rules in their present form were introduced from 6 April 2019 and may be referred to as the NRCGT 2019 regime. Other possible names for the regime are FA 2019 NRCGT