A disposal of direct or indirect interests in UK land (before 6 April 2019 and after 6 April 2015, a UK residential property interest) to a transferee who is not resident in the UK qualifies for relief1. This is because the disposal of such an interest by a non-resident is chargeable to capital gains tax (see C2.1131, C2.1136) so the held-over gain will not be taken outside the UK tax net (see C3.510).
The legislation indicates that the full amount of the gain that would otherwise have been chargeable may be held over in which case no chargeable gain arises at the time of the disposal. However, HMRC has expressed
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:03