The NRCGT rules charging gains on disposals by non-UK residents of direct or indirect interests in UK land are modified in the case of collective investment vehicles (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. For an overview of the NRCGT rules generally see C2.1139 and for an overview of the CIV rules see C2.1160. This article discusses the basic rules which apply in the absence of an election for transparency or exemption (for which see C2.1164 and C2.1165 respectively).
For capital gains purposes, all offshore CIVs apart from partnerships (or those that are
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Web page updated on 17 Mar 2025 17:24