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UK non-residents pay UK capital gains tax on disposals of UK land under rules known as the non-resident capital gains tax (NRCGT) regime. The regime applies to all persons: individuals, companies, trustees, personal representatives. Note that, despite the name of the regime, companies are subject to UK corporation tax on the gain in the normal way (TCGA 1992, s 2B(4); CG73920). Only individuals, trustees and personal representatives are subject to UK capital gains tax. Note that a personal representative is the person dealing with the administration of the estate of a deceased individual.

The general principle is that the following disposals of non-resident taxpayers are within the NRCGT regime:

1. Ìý

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

2. Ìý

   •ÌýÌýÌýÌý 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 UK non-resident has a substantial indirect interest in the land (eg the UK non-resident