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. For an overview of the NRCGT rules generally see C2.1139 and for an overview of the CIV rules see C2.1160. Certain offshore CIVs can elect to be exempt from corporation tax on chargeable gains accruing on direct and indirect disposals of UK land; see C2.1165. Where an election has
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