C2.1160 Property rich collective investment vehicles (CIVs)—overview
A gain arising on a direct or 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 see C2.1139.
While, in principle, these rules apply to all non-resident persons (including offshore collective investment vehicles(CIVs)), the rules are modified in the case of CIVs and their investors so as to limit the potential for multiple layers of UK taxation and any unintended consequences of the rules for exempt investors in offshore pension funds and similar vehicles.
The default position for offshore CIVs and their investors follows the general rules but on the assumption that
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Web page updated on 21 Mar 2025 09:41