The commentary below considers the exposure of various diplomats and members of armed forces posted to the UK from abroad to tax on capital gains. For an overview of the taxation of capital gains generally, see C1.101.
Diplomatic privileges
'Diplomatic agents' are exempt from capital gains tax except on gains from UK private immovable property, or UK investments made in commercial undertakings1. Where the diplomatic agent is taxable on those UK gains, the normal rules apply in relation to the calculation of the gain or loss and the amount of capital gains tax due.
A 'Diplomatic agent' is the head of the mission or a member of the diplomatic staff of the mission. The 'head of the mission' is the person charged by the foreign state with the duty of acting in that capacity. The 'members of the diplomatic staff' are the members of the staff of the mission having diplomatic rank. See E5.401A.2
Official agents of Commonwealth countries
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