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Home / Simons-Taxes /Personal and employment tax /Part E6 Overseas issues /Division E6.1 Residence status /Liability of non-residents / E6.129B Liability of non-residents to capital gains tax on disposals of UK residential property
Commentary

E6.129B Liability of non-residents to capital gains tax on disposals of UK residential property

Personal and employment tax

Historically only UK resident individuals and entities, together with temporary non-UK resident individuals and those operating via a UK permanent establishment, branch or agency, have been subject to UK capital gains tax (CGT) whilst non-UK residents have not. However, this was widened between 6 April 2013 and 5 April 2019 to include disposals of UK dwellings owned by non-resident companies, partnerships and collective investment schemes where the dwelling was subject to the annual tax on enveloped dwellings (ATED) charge1.

For details of the ATED-related CGT charge, see C2.1125–C2.1129. For details of the ATED-related CGT compliance regime, see C1.109.

Between 6 April 2015 and 5 April 2019, the CGT regime

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