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C2.1139 Non-resident CGT (NRCGT)—overview

Subject to certain exceptions, capital gains tax and corporation tax on chargeable gains are charged on gains made by UK residents (see C1.102 for a summary of the territorial scope of UK tax on chargeable gains). Two major exceptions (commonly known, collectively, as non-resident capital gains, non-resident CGT or NRCGT) are for gains made by non-UK resident persons where they arise on:

1. Ìý

   •ÌýÌýÌýÌý direct disposals of UK land (whether residential or non-residential), or

2. Ìý

   •ÌýÌýÌýÌý indirect disposals of UK land through disposals of rights or interests in companies that derive at least 75% of their value from UK land

The current rules apply to disposals on or after 6 April 2019 and replaced an earlier, more limited regime (see 'Background to the non-resident capital gains rules' below).

In order to prevent double taxation a gain is not chargeable under the NRCGT rules if it is already chargeable under TCGA 1992, ss 1B or 2C (non-resident with UK branch or agency, or non-resident company with UK permanent establishment, see C1.602), or