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C2.1145 Direct disposals of UK land by non-residents—overview

A gain arising on a direct 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 UK. For an overview of the NRCGT rules, including the applicable rates of tax, see C2.1139. For the meaning of non-residence, see C2.1140 and for the meaning of an interest in UK land, see C2.1141.

Although all types of direct disposals of UK land within the charge to tax, the distinction between residential and commercial property is relevant for two reasons:

1. Ìý

   •ÌýÌýÌýÌý where the property was acquired before 6 April 2019, the category of direct disposal is dependent on whether the property was either fully or partially residential before 6 April 2019 (see below). This, in turn, affects the computational