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.
A loss is generally an allowable loss for chargeable gains purposes only if a gain would have been a chargeable gain2. See C1.106 for further discussion of allowable losses. This article discusses when an allowable loss may arise to a non-UK resident and the rules for the setoff of allowable losses against NRCGT gains.
Capital gains tax losses
As non-UK residents subject to CGT (ie individuals, trustees and personal representatives) are only chargeable on gains arising from NRCGT disposals or disposals of UK assets connected with the non-resident's UK trade carried out through a branch or agency3 (see C1.201), it follows that only losses arising to a non-UK resident from such disposals are allowable losses. In relation to NRCGT
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