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. Although generally referred to as an indirect disposal of land, the gain or loss arises on the disposal of shares or other interests in the company which holds the land. The gain or loss is therefore calculated using the consideration received for the shares or interests being disposed of, rather than the value of the underlying UK land. The normal rules for share disposals therefore apply (for example, the substantial shareholding exemption may be available to corporate disposers,
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