A gain arising on an 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 UK. For an overview of the NRCGT rules for indirect disposals see C2.1150. The charge does not apply to disposals of rights or interests in property rich companies where the underlying UK land is used for the purposes of a qualifying trade. This article discusses this exemption in further detail.
The exemption is available where, at the time of the indirect disposal, it is reasonable to conclude that at least 90% of the market value of the UK land being disposed of is1:
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•ÌýÌýÌýÌý being used in or for the purposes of a 'qualifying trade', or
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•ÌýÌýÌýÌý if not currently being used, was acquired
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