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 applies on the disposal of an interest in a property-rich company but only where the non-resident person has a 'substantial indirect interest' in the company.
A non-resident person has a substantial indirect interest if they (together with persons connected to them) have held an investment of 25% or more in the company at any point in the two years prior to the disposal unless this was for an insignificant period1.
As a general rule, HMRC consider 'insignificant'
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