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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 third category of special rules covering mixed use properties and properties which have changed between residential and non-residential usage over the period of ownership before 6 April 2019.

A direct disposal of an interest in UK land is chargeable to tax under this category where it consisted of or included a dwelling at some time prior