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. There is a targeted anti-avoidance rule (TAAR) which applies to indirect disposals.
The TAAR is based on a motive test, which looks at whether a person has sought to obtain a tax
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