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 circumstances in which certain offshore CIVs can elect to be exempt from corporation tax on chargeable gains accruing on direct and indirect disposals of UK land.
The exemption election prevents multiple layers of tax by restricting any tax charge to the investor level only.
Persons eligible to make the exemption election
Provided certain qualifying conditions are met (see below), the following entities are eligible to make the exemption election1:
- Ìý
(a)ÌýÌýÌýÌý an offshore CIV that is a UK property rich company (including
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Web page updated on 17 Mar 2025 15:37