C2.1141 Non-Resident CGT (NRCGT) And Meaning Of An Interest In UK Land

Home / Simons-Taxes /Capital gains tax /Part C2 Computation of chargeable gains /Division C2.11 Land and interests in land /Disposals of interests in UK land by non-residents / C2.1141 Non-resident CGT (NRCGT) and meaning of an interest in UK land

Commentary

Capital gains tax

A gain arising on a direct or indirect disposal of an interest in UK land is chargeable to tax under the non-resident capital gains tax (NRCGT) rules where the person disposing of the property is not resident in the UK¹. For an overview of the NRCGT rules see C2.1139. For the meaning of non-UK resident see C2.1140.

For the purposes of both direct and indirect property disposals, an 'interest in UK land' means²:

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•�� an estate, interest, right or power in or over land in the United

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I4.265 Lifetime transfers reported late

I4.142A Liabilities which are not discharged out of the estate

I3.367 Fall in value relief—changes in interests in land

C3.1814A CGT exempt assets—qualifying corporate bonds (QCB)

B2.306 General tests for distinguishing between capital and revenue expenditure

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