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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 for direct disposals, see C1.108. The current regime applies to direct disposals of land on or after 6 April 2019 and applies, broadly, to tax only the gain arising from that date, or an earlier date where a disposal of the land would have been chargeable under the previous NRCGT regime. There are therefore special computational rules to achieve that outcome.

This article discusses the first category of special rules for direct disposals that only became chargeable as a result of the FA 2019 changes either because the type of UK land did not consist of a dwelling prior to 6 April 2019, and was therefore not chargeable, or where the person making the disposal was previously exempt.

Gains and