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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 or FA19 NRCGT.

For full details, see the Non-resident capital gains tax (NRCGT) on UK land ― individuals guidance note. It is recommended to read that